Fort Belvoir Spill Prevention, Control, & Countermeasure Plan

Fort Belvoir Spill Prevention, Control, and Countermeasure Plan

Prepared for:

Fort Belvoir Directorate of Public Works

Environmental Division

Prepared by:

Water Resources Division Army Public Health Center

ATTN: MCHB-IP-ESW, Building E-1675 5158 Blackhawk Road

Aberdeen Proving Ground, MD 21010-5403

September 2017

September 2017 Fort Belvoir SPCC Plan

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Table of Contents Page

ENGINEER'S CERTIFICATION ........................................................................... iv

MANAGEMENT APPROVAL ................................................................................ v

REVISION TRACKING FORM ............................................................................. vi

40 CFR 112 CROSS REFERENCE TABLE ........................................................ vii

1.0 INTRODUCTION ...................................................................................... 1-1

2.0 FACILITY DESCRIPTION ........................................................................ 2-1 2.1 General Information ........................................................................ 2-1 2.2 Containers Not Covered by this Plan .............................................. 2-2 2.3 Navigable Waters ............................................................................ 2-3

3.0 APPLICABILITY DETERMINATION ........................................................ 3-1

4.0 GENERAL PLAN REQUIREMENTS ........................................................ 4-1 4.1 Plan Review and Submittal ............................................................. 4-1 4.2 Conformance with Federal, Army, and Commonwealth of Virginia

Regulations ..................................................................................... 4-2 4.3 Personnel Training .......................................................................... 4-2 4.4 Security ........................................................................................... 4-3 4.5 Recordkeeping ................................................................................ 4-3 4.6 Spill History ..................................................................................... 4-3 4.7 Spill Response ................................................................................ 4-4 4.8 Inspection and Testing .................................................................... 4-7 4.9 Mobile and Portable Container Policy ............................................. 4-9 4.10 Rainwater Inspection in Diked Areas............................................. 4-13 4.11 Undiked Areas ............................................................................... 4-13 4.12 New Construction .......................................................................... 4-13 4.13 General Product Handling ............................................................. 4-13

5.0 CONTAINER AREAS ............................................................................... 5-1 5.1 Transportation Motor Pool (Building 190) ........................................ 5-3 5.2 300-Area Fuel Point (Building 324) ................................................. 5-7 5.3 300-Area Maintenance (Building 331) ........................................... 5-11 5.4 300-Area Pier (Buildings 338 and 341) ......................................... 5-15 5.5 600-Area (Building 606) ................................................................ 5-20 5.6 Recycling Center (Building 1089) .................................................. 5-24 5.7 Directorate of Public Works (DPW) Roads and Grounds

(Building 1114) ........................................................................... 5-27 5.8 Capitalized Fuel Station (Building 1124) ....................................... 5-31 5.9 Building 1128................................................................................. 5-35


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5.10 Army Air Force Exchange System (AAFES) Gas Station - South (Building 1135) .......................................... 5-38

5.11 Power Plant (Building 1234) .......................................................... 5-41 5.12 Motor Pool (Buildings 1417, 1419, and 1420) ............................... 5-46 5.13 Autocraft (Building 1462) ............................................................... 5-53 5.14 Marina (Building 1696) .................................................................. 5-57 5.15 Motor Pool (Buildings 1906 and 1956) .......................................... 5-60 5.16 Motor Pool (Buildings 1949 and 1950) .......................................... 5-65 5.17 AAFES Gas Station - South (Building 2304) ................................. 5-70 5.18 Earth Satellite (Building 2310) ....................................................... 5-73 5.19 Intelligence and Security Command (INSCOM) (Building 2444) ... 5-77 5.20 Defense Logistics Agency (DLA) (Building 2462) .......................... 5-81 5.21 Humphreys Engineer Center Support Activity (HECSA)

(Building 2580) ........................................................................... 5-85 5.22 2800-Area (Buildings 2800 and 2803) ........................................... 5-88 5.23 2800-Area (Building 2838) ............................................................ 5-92 5.24 Golf Course (Buildings 2909, 2990, and 2993) ............................. 5-95 5.25 Davison Army Airfield (DAAF) Hangar (Building 3121) ............... 5-102 5.26 DAAF Hangars (Buildings 3140 and 3144) ................................. 5-105 5.27 DAAF Hangars (Buildings 3151 and 3153) ................................. 5-108 5.28 DAAF Fuel Point (Building 3161) ................................................ 5-111 5.29 DAAF Hangars (Buildings 3231 and 3232) ................................. 5-116 5.30 National Geospatial-Intelligence Agency (NGA)

(Buildings 5103 and 5104) ....................................................... 5-119 5.31 Tulley Gate (Building 9500) ......................................................... 5-125 5.32 Electrical Transformers ............................................................... 5-128 5.33 Emergency Generators ............................................................... 5-131 5.34 Heating Oil Tanks ........................................................................ 5-143 5.35 Used Food Grease Containers .................................................... 5-150 5.36 Swimming Pool Chemical Containers ......................................... 5-155

6.0 CORRECTIVE ACTIONS ......................................................................... 6-1

Appendix A SPCC Regulated Containers and Underground Storage Tanks Appendix B Certification of the Applicability of the Substantial Harm Criteria Appendix C Discharge Report to US EPA Regional Administrator Appendix D Volume Calculations for Secondary Containment Dikes Appendix E Inspection Checklists Appendix F Immediate Actions Appendix G Reportable Quantities Appendix H Oil Spill Response Organizations Appendix I Satellite Locations SPCC Plans


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LIST OF FIGURES

Figure 2.1 Fort Belvoir Area Overview Map ................................................................. 2-4 Figure 2.2 Fort Belvoir Containers and Drainage Map (Area 1) .................................. 2-5 Figure 2.3 Fort Belvoir Containers and Drainage Map (Area 2) .................................. 2-6 Figure 2.4 Fort Belvoir Containers and Drainage Map (Area 3) .................................. 2-7 Figure 2.5 Fort Belvoir Containers and Drainage Map (Area 4) .................................. 2-8 Figure 2.6 Fort Belvoir Containers and Drainage Map (Area 5) .................................. 2-9 Figure 2.7 Fort Belvoir Containers and Drainage Map (Area 6) ................................ 2-10 Figure 3.1 Substantial Harm Criteria Flowchart........................................................... 3-2 Figure 5.1.1 Transportation Motor Pool (Building 190) ................................................ 5-4 Figure 5.2.1 300-Area Fuel Point (Building 324) .......................................................... 5-8 Figure 5.3.1 300-Area Maintenance (Building 331) .................................................... 5-12 Figure 5.4.1 300-Area Maintenance (Building 331) .................................................... 5-17 Figure 5.5.1 600-Area (Building 606) ......................................................................... 5-21 Figure 5.6.1 Recycling Center (Building 1089) ........................................................... 5-25 Figure 5.7.1 DPW Roads and Grounds (Building 1114) ............................................ 5-28 Figure 5.8.1 Capitalized Fuel Station (Building 1124) ................................................ 5-32 Figure 5.9.1 Building 1128 ......................................................................................... 5-36 Figure 5.10.1 AAFES Gas Station - South (Building 1135) ........................................ 5-39 Figure 5.11.1 Power Plant (Building 1234) ................................................................. 5-43 Figure 5.12.1 Motor Pool (Buildings 1417, 1419, and 1420) ...................................... 5-49 Figure 5.13.1 Autocraft (Building 1462)...................................................................... 5-54 Figure 5.14.1 Marina (Building 1696) ......................................................................... 5-58 Figure 5.15.1 Motor Pool (Buildings 1906 and 1956) ................................................. 5-62 Figure 5.16.1 Motor Pool (Buildings 1949 and 1950) ................................................. 5-67 Figure 5.17.1 AAFES Gas Station - South (Building 2304) ........................................ 5-71 Figure 5.18.1 Earth Satellite (Building 2310) .............................................................. 5-75 Figure 5.19.1 INSCOM (Building 2444) ...................................................................... 5-79 Figure 5.20.1 DLA (Building 2462) ............................................................................. 5-83 Figure 5.21.1 HECSA (Building 2580) ........................................................................ 5-86 Figure 5.22.1 2800-Area (Buildings 2800 and 2803) ................................................. 5-90 Figure 5.23.1 2800-Area (Building 2838) ................................................................... 5-93 Figure 5.24.1 Golf Course (Building 2909) ................................................................. 5-98 Figure 5.24.2 Golf Course (Buildings 2990 and 2993) ............................................... 5-99 Figure 5.25.1 DAAF Hangar (Building 3121) ............................................................ 5-103 Figure 5.26.1 DAAF Hangars (Buildings 3140 and 3144) ........................................ 5-106 Figure 5.27.1 DAAF Hangars (Buildings 3151 and 3153) ........................................ 5-109 Figure 5.28.1 DAAF Fuel Point (Building 3161) ....................................................... 5-113 Figure 5.29.1 DAAF Hangars (Buildings 3231 and 3232) ........................................ 5-117 Figure 5.30.1 NGA (Buildings 5103 and 5104) ........................................................ 5-122 Figure 5.31.1 Tulley Gate (Building 9500) ................................................................ 5-126


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40 CFR 112 CROSS REFERENCE TABLE

Final SPCC Rule Rule Requirement

Equivalent Section

§ 112.3(d) PE certification Engineer’s Certification

§ 112.3(e)(1,2) Facility maintains copy of plan 1.0

§ 112.3(f) Extension of time 6.0

§ 112.4 Submittal requirements to the EPA Region II administrator 4.1

§ 112.5(a) Updating requirements 4.1

§ 112.5(b) Plan reviewed at least once every five years 4.1

§ 112.7 Cross-reference table to the parts of the regulation Cross

Reference Table

§ 112.7 Facility management approval Management Approval

§ 112.7(a)(1,2) Conformance with the regulations, details on equivalent environmental protection

4.2, 4.8, 4.9, 5.9

§ 112.7(a)(3)(i)Plot plan showing the location and contents of each container, exempted USTs, piping, and transfer station

Figure 2.1, Figures in Section 5

§ 112.7(a)(3)(ii) Discharge prevention and product handling 4.13, 5.x.2*

§ 112.7(a)(3)(iii) Discharge controls and secondary containment 4.7, 5.x.3*

§ 112.7(a)(3)(iv-vi)

Discharge countermeasures, disposal, and notification 4.7

§ 112.7(b) Prediction of potential discharge (direction, rate of flow, amount)

Figure 2.1, Figure 2.2,

5.x.5*

§ 112.7(c) Secondary containment 4.11, 5.x.3*

§ 112.7(d) Contingency planning 4.7, 5.9

§ 112.7(e) Inspections, tests, and records 4.5, 4.8, 4.9, 5.x.4*

*Note that “5.x” indicates a subsection in each Container Area described under Section5 of the Plan.


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40 CFR 112 CROSS REFERENCE TABLE (Continued)

Final SPCC Rule Rule Requirement

Equivalent Section

§ 112.7(f)(1) Personnel training program requirements 4.3

§ 112.7(f)(2) Accountability for discharge prevention 1.0

§ 112.7(g) Security 4.4

§ 112.7(h) Loading/unloading 5.x.2*

§ 112.7(i) Brittle fracture evaluation requirements N/A

§ 112.7(j) Conformance with State requirements N/A

§ 112.7(k) Qualified oil-filled operational equipment 5.9, 5.12

§ 112.8(b) Facility drainage 2.3, Figures 2.1-2.7, 4.11

§ 112.8(c)(1) Compatible bulk storage containers 2.1

§ 112.8(c)(2) Bulk storage containers secondary containment 2.1, 5.x.3*

§ 112.8(c)(3) Requirements for drainage of diked areas 4.10

§ 112.8(c)(4) Cathodic protection for buried tanks N/A

§ 112.8(c)(5) Cathodic protection for partially buried tanks N/A

§ 112.8(c)(6) Inspections and integrity testing for aboveground containers 4.8, 4.9, 5.x.4*

§ 112.8(c)(7) Monitor internal heating coils N/A

§ 112.8(c)(8) High level alarm requirements 5.x.2*

§ 112.8(c)(9) Observe effluent treatment facilities N/A

§ 112.8(c)(10) Correct visible discharges 4.7

§ 112.8(c)(11) Locate mobile containers in secondary containment 4.9

§ 112.8(d) Facility transfer operations, pumping, and facility process 4.13, 4.8

§ 112.20(e) Certification of Substantial Harm Criteria 3.0, Appendix B

*Note that “5.x” indicates a subsection in each Container Area described under Section5 of the Plan.


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1.0 INTRODUCTION

The Oil Pollution Prevention regulations, administered under the authority of the United States Environmental Protection Agency (US EPA), require certain facilities to prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan to reduce or eliminate oil discharges to navigable waters of the United States. SPCC Plans document regulated containers at a facility and the inspection, testing, and maintenance procedures for those containers. The SPCC Plan also contains information regarding emergency response actions.

This document is the SPCC Plan (or Plan) for Fort Belvoir, located near Alexandria, Virginia. This Plan has been prepared in accordance with 40 CFR 112 as amended. This Plan includes references to industry standards that apply to containers at Fort Belvoir, and has been certified by a Professional Engineer registered in the State of Maryland.

Section 2.0 describes the installation and the surrounding area. The applicability of the SPCC regulations is described in Section 3.0. Section 4.0 contains general information required to be in any approved SPCC Plan. Facility contacts and spill response procedures are located in Section 4.7. Section 5.0 describes individual container storage areas. Section 6.0 contains the schedule for implementing any required facility changes.

The SPCC Program Manager in the Directorate of Public Works (DPW), Environmental Division, is responsible for maintaining this Plan and discharge prevention. A copy of this Plan is maintained onsite in the DPW Environmental Division Office. The container areas in Section 5 also have copies of their respective sections.


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2.0 FACILITY DESCRIPTION

2.1 General Information

Fort Belvoir is on an 8,700-acre plot along the western bank of the Potomac River. The installation is about 11 miles southwest of Alexandria, 14 miles southwest of Washington, D.C, and 95 miles north of Richmond, Virginia.

Fort Belvoir’s primary mission is to provide support services to activities and tenants located at Fort Belvoir and throughout the National Capital Region. The mission includes: regional administrative, logistics, recreation, housing, and contingency military support.

Fort Belvoir is located in Fairfax County, near Alexandria, Virginia, at 38° 41’ North latitude; 77° 08’ West longitude.

The following SPCC-regulated oils are used on Fort Belvoir:

• Gasoline• Diesel• Heating Oil• Kerosene• JP8• Engine Oil• Hydraulic Oil• Grease• Mineral Oil• Vegetable Oil and Grease• Used Oils and Sludges

These products are stored in a variety of containers including underground storage tanks (USTs), aboveground storage tanks (ASTs), electrical operating equipment, emergency generator day tanks, 55-gallon drums, and smaller containers. All containers that hold 55-gallons or more of SPCC-regulated oils are considered SPCC-regulated containers with the exception of regulated USTs, see section 2.2 below. Appendix A lists specific information for the SPCC regulated containers at Fort Belvoir. All of the regulated containers are designed to be compatible with the materials stored and operate at ambient temperatures and pressures. Secondary containment structures are sufficiently impervious to the oils they are intended to contain. No containers use internal heating coils. Fort Belvoir does not have any field-constructed


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tanks. Fort Belvoir is a RCRA large quantity generator and, therefore, requires a RCRA contingency plan. Building 1495 is the RCRA less than 90-day storage facility. It has a RCRA Contingency Plan, prepared October 2014. Also, there are no polychlorinated biphenyl (PCB) oil storage containers or PCB-containing devices (transformers, ballasts, etc.) onsite.

2.2 Containers Not Covered By this Plan

Containers owned and operated by contractors temporarily working on Fort Belvoir property are not covered by this Plan. Such containers may include fuel tanker trucks or ASTs temporarily brought onto Fort Belvoir. Each contractor is responsible for determining SPCC applicability and developing a site-specific Plan if necessary. Although not included in the SPCC Plan, related spill response activities may still involve Fort Belvoir personnel.

USTs subject to all the technical requirements of 40 CFR 280 (see Appendix A, Table A-2) are exempt from all SPCC requirements. However, they must be shown on the Containers and Drainage Maps (Figures 2.2 to 2.7) and are listed in Table A-2 in Appendix A. There is one UST (2849D) listed in the Appendix that was installed but has never been used and will never be used. However, it was pre-registered as an UST. This tank could be removed from all listings and maps if the registration was nullified.

There are oil/water (O/W) separators at various locations on Fort Belvoir. The O/W separators are slow flow, gravity separation chambers used for primary treatment of industrial wastewater to remove free oil, grease, and fuel. Treated effluent discharges to the sanitary sewer system. The collected oil is periodically removed by a contractor. DPW personnel conduct periodic inspections and maintenance on the O/W separators to ensure proper operation. These O/W separators are exclusively used for wastewater treatment and are excluded from regulation by 40 CFR 112.

Amendments to 40 CFR 112 (from 26 December 2006) exempt all “motive power” containers (such as vehicle gas tanks) from SPCC Plan requirements. DoD recommends that the containment methods listed under 40 CFR 112.7(c) be employed as much as practicable for vehicle gas tanks and other such tanks over the 55-gallon threshold. Spills from these types of sources can be addressed under the description of undiked areas. Fort Belvoir operates equipment affected by this guidance including tactical vehicles, construction vehicles, and tractor-trailer trucks. (See Section 4.11 for more details regarding Undiked Areas).


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Fort Belvoir is also responsible for satellite locations, including Rivanna and the Mark Center, that are geographically distinct and effectively not under direct management of daily operations. These are considered separate facilities for SPCC Plan purposes. These sites have their own SPCC Plans as required by 40 CFR 112. The NGA also has a separate SPCC Plan but this satellite location is closer and more directly linked to the Fort Belvoir Garrison and is thus included in this SPCC Plan too. Copies of the satellite location SPCC Plans are in Appendix I.

2.3 Navigable Waters

Fort Belvoir is surrounded on its eastern, western, and southern borders by the Potomac River and its tributaries, Dogue Creek, and Accotink Creek (which widens into Accotink Bay and Gunston Cove). Drainage discharges to Dogue Creek or Accotink Creek (through Gunston Cove) and eventually discharges to the Potomac River and then the Chesapeake Bay. Various towns in Fairfax County discharge municipal storm water to Dogue Creek and Accotink Creek upstream of Fort Belvoir. See Fort Belvoir Area Overview Map, Figure 2.2 for details.

Some of Fort Belvoir’s territory is within a recognized flood zone. The Federal Emergency Management Agency maps of the 1 percent annual likelihood flood area (also known as the 100-year flood) include areas near Accotink Creek (including the entire northeast side of Davison Army Airfield, portions of Pohick Road and nearly up to Building 1495, the RCRA less than 90-day facility) on Fort Belvoir’s main cantonment area western boundary, near the Potomac River on the southern end of Fort Belvoir (300-Area pier) and the eastern bank of Dogue Creek (near the marina) in the easternmost portion of Fort Belvoir.


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Figure 2.1 Fort Belvoir Area Overview Map


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Figure 2.2 Fort Belvoir Containers and Drainage Map (Area 1)


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2-7



2-8



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3.0 APPLICABILITY DETERMINATION

According to 40 CFR 112.1, Fort Belvoir requires an SPCC Plan. The facility-wide aboveground oil storage capacity totals more than 1,320 gallons, and oil discharges could reach navigable waters.

Army Regulation (AR) 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan addresses secondary containment (or lack thereof) at oil and hazardous material storage facilities.” This Plan includes hazardous materials storage sites.

40 CFR 112.20(e) requires that affected facilities determine their potential to cause substantial harm and file a Facility Response Plan with the EPA Regional Administrator, if necessary. Figure 3.1 shows the Flowchart of Criteria for Substantial Harm from Attachment C-1, Appendix C, 40 CFR 112. This flowchart asks several questions regarding facility processes and storage capacity. As required by 40 CFR 112.20(e), the Certification of the Applicability of the Substantial Harm Criteria is included in Appendix B of this Plan. Fort Belvoir has less than one million gallons of oil storage capacity (approximately 700,000 gallons) and does not transfer oil over water to/from vessels and does not pose a threat of substantial harm to fish and wildlife, a sensitive environment, or a drinking water intake. Therefore, a Facility Response Plan is not required.


3-2

SUBMIT RESPONSE PLAN YES SUBMIT RESPONSE

PLAN Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons?

Does the facility have a total oil storage capacity greater than or equal to 1 million gallons?

NO SUBMITTAL OF RESPONSE PLAN EXCEPT AT RA DISCRETION

Within any aboveground storage tank area, does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation?

Is the facility located at a distance such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments?

Is the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake?

Has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last five years?

NO

NO

NO

NO

YES

NO

NO

YES

YES

YES

YES

Figure 3.1 Substantial Harm Criteria Flowchart


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4.0 GENERAL PLAN REQUIREMENTS

4.1 Plan Review and Submittal

This Plan must be reviewed and evaluated at least once every five years. This Plan must be amended within six months of the review if more effective, field-proven prevention and control technologies that would significantly reduce the likelihood of a discharge are available at the time of the review. If there are any technical amendments to the Plan, then a Professional Engineer must recertify it. Technical amendments include physical modifications, or changes in facility procedures. If all changes are non-technical (e.g., contact name, phone number, container identification number, etc.), DPW Environmental personnel can review the Plan and sign the revision tracking form on page v.

This Plan must also be updated whenever there is a change in the facility design, construction, operation, or maintenance that materially affects its discharge potential. These types of changes include, but are not limited to, commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures. Movement of containers within an area that does not increase either the likelihood or the potential severity of a discharge would not require an update to the Plan.

Required Plan amendments must be prepared within six months of the change in operation, and implemented as soon as possible, but not later than six months following preparation of the amendment. The revisions page at the beginning of this Plan must be updated to include all technical and non-technical changes to the Plan.

A report must be submitted to the US EPA Regional Administrator only if Fort Belvoir has:

• Discharged more than 1,000 gallons of oil in a single discharge or

• Discharged more than 42 gallons of oil in each of two discharges,occurring within any twelve-month period.

40 CFR 112.4(a) lists the information that must be submitted to the US EPA Regional Administrator no more than 60 days from the date of the discharge that required the submittal. This required information is also presented in Appendix C. The Regional Administrator may also require that the SPCC Plan be submitted for review.


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4.2 Conformance with Federal, Army, and Commonwealth of Virginia Regulations

The main purpose of this Plan is to comply with the requirements of 40 CFR 112. However, Army Regulation (AR) 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan addresses secondary containment (or lack thereof) at oil and hazardous material storage facilities.” So this Plan also includes hazardous material storage sites.

The Commonwealth of Virginia has additional requirements [9 Virginia Administrative Code (VAC) 25-91] more stringent than the Federal requirements in regards to ASTs and spill contingency plans. ASTs in Virginia are required to be registered with the state; the DEQ must be notified of major repairs or changes to ASTs; AST operator inspectors require additional training; AST closures must include a site assessment to evaluate potential soil, surface water, or groundwater contamination; secondary containment must be evaluated and certified by a PE; and ASTs must also have storage capacity, product stored, and tank identification number labeled on the tank. All of these requirements are applicable only to ASTs with volumes of greater than 660 gallons that are not an integral part of an emergency generator (base tank, belly tank). Section 4.7, Inspection and Testing includes additional requirements and exclusions.

4.3 Personnel Training

As required by 40 CFR 112.7(f)(1 and 3), oil handling personnel are trained to prevent discharges. Fort Belvoir conducts SPCC Plan training on an annual basis for all oil-handling personnel. This training includes a review of this SPCC Plan, applicable pollution control laws, spill response procedures, inspection and recordkeeping requirements, and the spill history for Fort Belvoir. Personnel also receive specific training in petroleum product handling procedures and equipment maintenance and operation. Fort Belvoir Directorate of Logistics (DOL) personnel responsible for fuel transfers receive additional training commensurate with their specific job requirements. Records of additional training are maintained by individual units or activities. The additional training may include:

• Occupational Safety and Health Administration (OSHA) Hazardous WasteOperations and Emergency Response (29 CFR 1910.120),

• OSHA Hazard Communication Standard (29 CFR 1910.1200),

• OSHA Process Safety Standard (29 CFR 1910.119),


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• Resource Conservation and Recovery Act (RCRA) Personnel Training (40 CFR265.16),

• RCRA Waste Handling / Emergency Procedures (40 CFR 262.34(d)), and

• Department of Transportation Hazardous Materials Training (49 CFR 172,Subpart H).

Further training for personnel inspecting ASTs is required by 9VAC25-91. Thetraining must include occupational safety, hazard recognition, personnel protection, facility operations, and procedures for conducting inspections, evaluating AST condition, and responding to identified hazards.

4.4 Security

Fort Belvoir is a fenced military installation. Access requires positive identification and all vehicles are subject to random searches. This level of security helps ensure that oil storage areas are only accessed by authorized personnel. In addition, military police conduct roving patrols throughout the installation. All pump starter controls are locked off when not in use and are only accessible to authorized personnel. Outdoor fuel dispensers are disabled after operating hours. All container areas have adequate facility lighting.

4.5 Recordkeeping

DPW Environmental maintains regular inspection and test records in accordance with 40 CFR 112.7(e); these records are maintained for a minimum of three years. DPW Environmental also maintains inspection and testing records for certified inspections for the life of the container. General inspection and testing procedures for containers are described in more detail in Sections 4.8 and 4.9. Exceptions to the general procedures are identified in individual container area descriptions in Section 5 of this Plan.

4.6 Spill History

The Fort Belvoir spill history is maintained by DPW Environmental with dates, quantities, and corrective actions for all spills during the last five years. Records of all spills over 5 gallons, whether they are a reportable quantity or not, are maintained in the spill log. The spill log must be reviewed annually to assess spill response and evaluate existing procedures.


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4.7 Spill Response

If a spill occurs, installation personnel follow the response, reporting, and cleanup procedures appropriate to the level of spill. Personnel, if properly trained and equipped to do so safely, will promptly correct and cleanup (using available absorbents or spill kits) any visible POL discharges less than 5 gallons which are still on an impervious surface. All POL spills of any size that contact the ground, surface water, storm drains, or the sanitary sewer; POL spills greater than 5 gallons; or any size spills of a hazardous material (even on impervious surfaces) are called in to the Fort Belvoir Fire Department immediately. Table 4.1 indicates the response for various spills. The Fort Belvoir Fire Department is the primary spill responder and can be reached on any installation phone by dialing 911.

Spill reporting may include notifications to the National Response Center (NRC), the Virginia Department of Environmental Quality (DEQ), the Virginia Emergency Response Commission, and Installation Management Command (IMCOM). The US EPA does not distinguish between types of oil, and any spill that causes a sheen upon “navigable waters” or that violates applicable water quality standards must be reported to the NRC (40 CFR 110.6). DPW Environmental is responsible for all reporting to external agencies. For Fort Belvoir, this means that the NRC must be called if an oil spill reaches Accotink Creek/Bay, Dogue Creek/Bay, the Potomac River, any associated wetlands, or their tributaries as shown on Figures 2.1 and 2.2.

Hazardous materials used at Fort Belvoir are listed in Appendix G. Their reportable quantities (RQs) and largest container sizes are also listed. One herbicide monosodium methanearsonate (known as MSMA) at the Golf Course (Building 9293) and sodium hypochlorite solutions at Buildings 2444 and 5104 are stored in large enough containers to potentially require reporting. It should be noted that there are also some hazardous materials that may not have RQs established, and that spills below the RQ for some hazardous materials could still cause environmental harm.


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Table 4.1a Spill Response and Reporting Procedures

Spill Volume Response Reporting Hazardous Material

Less than RQ or still on impervious surface within

containment

Fire Department DPW Environmental

Hazardous Material Greater than RQ that leaves

containment Fire Department

NRC, Virginia DEQ, Virginia Department of Emergency

Management, IMCOM, DPW Environmental

Less than 5 gallons of POL contained on impervious

surface Onsite Personnel None

Greater than 5 gallons of POL contained on impervious surface

Onsite Personnel and Fire Department DPW Environmental

Any amount of POL that reaches ground surface Fire Department DPW Environmental

Any amount of POL that reaches a navigable water Fire Department NRC, Virginia DEQ, DPW

Environmental Greater than 25 gallons of

POL in a single event Fire Department NRC, Virginia DEQ, DPW Environmental

Spill to Sewer System Fire Department Fairfax County Lower Pollution Control Plant

Table 4.2 Spill Reporting Agencies

Agency Phone National Response Center (800) 424-8802 Virginia DEQ (703) 583-3800 Virginia Department of Emergency Management (800) 468-8892

Fairfax County Virginia Fire Department

Woodlawn 911 or (703) 780-0110 Gunston 911 or (703) 339-5970

Fairfax County Lower Pollution Control Plant (703) 323-1211 IMCOM (404) 464-0709 Fort Belvoir Fire Department 911 or (703) 806-1800

Fort Belvoir DPW Environmental (703) 806-3694 or (703) 806-0020 or (703) 806-2119


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The information in Table 4.3 should be reported after a spill. Spill response equipment is maintained throughout the installation, including the Fort Belvoir Fire Department [Buildings 191 (South), 2119 (North), 3237 (DAAF), and 5100 (NGA)], 300-Area Pier (Buildings 338 and 341), DPW Roads and Grounds (Building 1114), Capitalized Fuel Station (Building 1124), AAFES gas stations (Buildings 1135 and 2304), DPW motor pool (Building 1420), autocraft (Building 1462), less than 90-day storage facility (Building 1495), motor pools (Buildings 1949 and 1950), golf course (Building 2990), DAAF Fuel Point (Building 3161), NGA (Building 5103).

The Fire Department response trucks contain sufficient materials to respond to, safely contain, and completely clean-up a spill of 300 gallons. There are enough fully encapsulating protective suits for an entire shift to don simultaneously. Two overpack drums and side cabinets and boxes contain oil absorbent booms, sheets, pads, and socks. The hazmat trailers, which are not attached to the response trucks, have approximately double the amount of response equipment. The trailers are adequate for spills of 1,000 gallons. The Fire Department does not clean-up spills, they contain and control spills to maintain public safety. Spills are cleaned up by installation maintenance contractor personnel. Some areas also have separate maintenance contractors that include spill clean-up. For larger spills, the DPW Roads and Grounds has approximately five pallets of oil absorbent compounds as well as containers (steel drums, plastic drums, and overpack drums), tools (shovels, rakes, picks, etc.), and earthmoving equipment (bulldozers, backhoes, excavators, etc.). Oil spill response organizations (OSROs) can also be contracted if there is a large amount of cleanup required. The decision to call in OSROs would be made by the incident commander (the senior fire department officer on-scene). Funding mechanisms (approval, contracting, accounting, etc.) need to be set up to allow for potential emergency use (see Appendix H for OSRO contactors). Recovered oils are managed as used oil or used fuel if they can be separated in liquid form. Recovered oils that are mixed with soil are managed as non-hazardous regulated waste and as hazardous waste if contaminated with other chemicals (complex mixtures, unknowns, highly flammables/toxics, etc.). The DPW Environmental POL and Hazardous Waste Managers and RCRA less than 90-day facility personnel will make determinations on the management of spill related wastes. The Fairfax County Fire Department can be called to assist with complex or burning spills.


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Table 4.3 Spill Reporting Information

Individual Reporting Spill

Name and Address

Fort Belvoir DPW Environmental Division (IMBV-PWE) U.S. Army Garrison Fort Belvoir, VA 22060

Phone

Date and time of spill

Type of material discharged

Location of the spill

Quantity discharged (estimate) and time/duration of the event

Name of any surface water involved or threatened

The source of the discharge

Description of all affected media (soil, water, vegetation)

Cause of the discharge

Possible hazards to the environment

Any damages or injuries caused by the discharge

Any known or anticipated health risks associated with the incident Actions being used to stop, remove, and mitigate the effects of the discharge

Whether an evacuation may be needed

Individuals or organizations contacted

Name Organization Time of Call


4-8

4.8 Inspection and Testing

Inspection and testing of tanks is required by 40 CFR 112.8(c)(6). The inspection and testing procedures for regulated containers in this Plan are based on applicable industry standards. Mobile and portable tank (including 55-gallon drum) inspection and testing requirements are described in section 4.9. The Steel Tank Institute (STI) Standard SP001-05 (September 2011 revision) applies to stationary shop-built tanks. This standard requires combinations of periodic inspections by owners, certified inspections for the interior and exterior of ASTs, and certified integrity (leak) tests at varying intervals depending on the volume and structure of the AST and secondary containment. Integrity tests are not required for shop-built ASTs with double-walls and volumes of less than or equal to 5,000 gallons. Instead, the STI Standard calls for inspection of the interstitial space and verification of the leak detection system.

Monthly AST inspections include the full length of piping associated with the AST. This is a much greater frequency of piping inspection than required by American Petroleum Institute Piping Inspection Code 570 (every 5 years or as determined by risk based analysis). In addition, if underground piping becomes exposed during excavation, construction, or demolition, a visual inspection for corrosion is required. If corrosion is found, then immediate corrective measures are undertaken (such as protective wrapping and coating or pipe replacement) and further excavation is completed to more fully examine the piping. 40 CFR 112.8(c)(8)(v) also requires verification of liquid level sensors on all bulk storage containers, which are tested monthly. Table 4.4 shows the documented inspections required of all bulk storage tanks and piping. Inspection checklists are in Appendix G. Section 4.5 describes recordkeeping procedures.

Table 4.4a AST and Piping Inspection and Testing

Inspection/Test Standard Method Frequency

Presence of water in primary tank

STI SP001-05, Appendix C Sampling Monthly

Presence of water, oil, or debris in secondary containment

STI SP001-05, Appendix C Manual Monthly

Operation of leak detection system


Piping connections and openings properly sealed

STI SP001-05, Appendix C Visual Monthly


4-9


Drain valves operable and in closed position


Operation of liquid level sensor STI SP001-05, Appendix C Manual Monthly

Visible signs of leakage, corrosion, or damage

STI SP001-05, App C and

API 570, App D Visual Monthly

Exterior and coating deterioration/corrosion/distortion

STI SP001-05, Appendix C Visual Yearly

Operation and cleanliness of operating and emergency vents


Emergency vent gasket STI SP001-05, Appendix C Visual Yearly

Proper drainage around tank STI SP001-05, Appendix C Visual Yearly

Tank supports, pad, and foundation damage


Tank grounding and electrical wiring


Operation of overfill protection devices


Certified STI Inspection (Not required of double-walled tanks - 5,000 gallons or less)

STI SP001-05, Appendix C

Enhanced visual and

records review 20 Years

All ASTs with volumes greater than 660 gallons must also be inspected in accordance with Virginia regulation (9VAC25-91-130). There are two exclusions to this regulation that apply at Fort Belvoir: heating oil tanks, which only require the Virginia inspections at greater than 5,000 gallons; and tanks that are an integral part of a generator and the fuel is only used by the generator (e.g. belly tanks). Tanks 246D, 324R, 324T, 765A, 765B, 1114A, 1956B, 2810D, 3138J, and tanks 5104A to 5104G are required to meet these additional inspection requirements. The tanks listed above are exempt from Virginia requirements for inventory control and variability analysis, because the tanks and associated piping are completely off the ground [9VAC25-91-130.B.1(a)(1)]. The requirements, listed in Table 4.4b below, as well as those listed in Table4.4a above, will be met for each of these tanks.


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Table 4.4b Additional Inspection/Test Schedule for Tanks 246D, 324R, 324T, 765A, 765B,

1114A, 1956B, 2810D, 3138J, and Tanks 5104A to 5104G

* - Daily inspections must include: complete walk-throughs of the areas to assure nohazardous conditions exist; ground inspections for signs of spills/leaks or stains; a check of the containment for water and closed valves; visual inspections of the tank exteriors for damage/leakage; and evaluations of the tanks’ appurtenances.

# - Weekly inspections must be conducted using checklists that include the following minimum items: inspection of secondary containment condition; containment free of oil or water; containment valves secured; containment area free of debris; tank shell surface, including welds, rivets, bolts, seams, and foundation, inspected for rust or other deterioration; ground surface checked for signs of leakage; leak detection operational; separator or drainage tank in satisfactory condition; tank bottom water draw-offs secured; tank fill valves secured; valves inspected for signs of leakage or deterioration; piping and flanges inspected for leakage; and tank gauges inspected and operational.

Containers (drums and ASTs) of chemicals not regulated by 40 CFR 112, because they do not contain oil, are regulated by AR 200-1. AR 200-1 does not have requirements for container integrity testing or inspections. However, it would be a good management practice to visually inspect chemical containers for visible leaks and signs of areas of corrosion, wear, cracking, material thinning, and tightness/alignment of piping, fittings, connections, and gaskets as well as operability of gauges, pumps, and valves.

4.9 Mobile and Portable Container Policy

Fort Belvoir is implementing this policy to manage oils and fuels stored in drums, portable containers, and mobile containers with an oil storage capacity between 55-gallons and 2,000 gallons. Portable containers are typically mounted on skids or saddles and may remain in place for an extended period of time; 55-gallon drums are

Inspection/Test Standard Method Frequency Visual Inspection* 9VAC25-91-

130.B.5.a Visual Daily

Visual Inspection# 9VAC25-91-130.B.5.b Visual Weekly

Pressure Testing of Piping 9VAC25-91-130.B.4.b

Hydrostatic or API 570 5 years


4-11

also considered portable containers. Mobile containers are mounted to frames with wheels. Examples of mobile containers include fuel pods, mobile generator fuel tanks, and tanker trucks. Personnel frequently move these containers or alter the number of containers in a particular area. For this reason, the exact location of each drum, portable container, or mobile container is not included in this Plan. However, the areas that are commonly used for storage of drums or other mobile and portable containers (and the maximum allowable volume of POL products stored in those areas) are identified in this Plan.

All containers covered by this Mobile and Portable Container Policy must have the means available to prevent discharges to navigable waters. This may include spill kits or spill pallets, diked storage areas, and/or storing containers inside a building. Secondary containment is required when containers covered under this policy are stationary and not in use for at least four consecutive hours.

Inspection and testing of all bulk storage tanks is required by 40 CFR 112.8(c)(6). The inspection and testing procedures for regulated containers in this Plan are based on consideration of applicable industry standards. Mobile and portable tank (including 55-gallon drum) inspection and testing requirements are contained in STI Standard SP001-05 (September 2011 revision). This standard requires periodic inspections by owners and recertification to Department of Transportation (DOT) standards at varying intervals, depending on the material of construction and secondary containment used. Inspection checklists are in Appendix E.


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Table 4.5 Mobile and Portable Container Inspections and Testing


Presence of water in primary tank

STI SP001-05, Appendix C Sampling Monthly

Presence of water, oil, or debris in interstice or

secondary containment


Operation of leak detection system

(Double-walled tanks only)


Visible signs of leakage or corrosion/distortion


Piping connections and openings properly sealed


Drain valves operable and in closed position


Operation of liquid level sensor


DOT recertification and leak testing

(required only if no secondary containment is

used)

49 CFR 173.28

49 CFR 178.803

49 CFR 180.605

Hydrostatic Test, Mass

Measurement, Level

Measurement, Pressure

Decay, etc.

Plastic -Every 7 Years

Steel – Every 12

Years

Stainless Steel –

Every 17 Years

Records of external inspections are maintained for at least three years. Records of integrity tests shall be maintained for the life of the container. Fort Belvoir does not intend to keep any drums beyond the DOT recertification test period. Personnel will track the container's age if a mobile/portable tank or drum is to be used for more than the DOT recertification test period (see Table 4.5). Records of monthly visual inspections are maintained for at least three years.


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4.10 Rainwater Inspection in Diked Areas

Some containers are surrounded by secondary containment dikes. Installation personnel drain rainwater from these diked areas through locked, manually activated valves. Prior to release, personnel verify that an oil sheen is not present on the surface of the collected rainwater. If a sheen is present, personnel take appropriate action for reporting and cleanup. Site personnel also maintain a drain log recording the date and volume of rainwater that is released from the diked areas.

4.11 Undiked Areas

The SPCC regulations in 40 CFR 112.8(b) require facilities to prevent potential discharges from undiked areas by designing drainage systems that flow into catchment basins or lagoons. This does not apply to Fort Belvoir. The limited potential for spills outside of typical fuel handling areas does not warrant a complete redesign of the existing drainage system. Fort Belvoir’s spill response capabilities as described in Section 4.7, proper personnel training as described in Section 4.3, and periodic inspections as described in Sections 4.8 and 4.9 should be adequate to prevent and contain discharges associated with typical failure mode (most likely to be a small drip or leaks from small bore suction piping that only contains oil when an emergency generator is activated) from undiked areas. A spill kit with absorbents would be able to contain and clean up this quantity of oil. This qualifies as equivalent environmental protection (as allowed under 40 CFR 112.7(a)(2)).

Fuel tanks (greater than 55 gallons) on some vehicles and larger equipment are exempt from SPCC plan requirements because they are considered “motive power containers”. Spills from these containers may occur in undiked areas. Spill response will follow the procedures outlined in Section 4.7.

4.12 New Construction

Any new construction will comply with the applicable requirements of 40 CFR 112.8(d). New buried metallic piping will either have a protective coating or cathodic protection. In the event that piping is exposed during an excavation, the pipe will be inspected for corrosion and repaired or replaced as necessary.

4.13 General Product Handling

Installation personnel follow standard operating procedures for product handling as listed in applicable military standards. In general, personnel follow the spill prevention procedures below when transferring product to or from a tanker truck:


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• Load or unload in approved locations only

• Establish communications between the pumping and receiving stations

• Verify that the available volume of the receiving container is greater than thevolume of oil to be transferred

• Continuously monitor the entire oil transfer

• Properly close all drainage valves for any secondary containment

• Allow sufficient volume (approximately 10% of the total capacity) in the receivingcontainer for thermal expansion

• Visually inspect all valves for leakage when transfer is complete


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5.0 CONTAINER AREAS

This section of the Plan provides details about SPCC-regulated containers in each area. An area typically encompasses all the containers owned and maintained by a single shop or functional unit. Heating oil tanks, transformers, generators, and used food grease containers have been grouped as “areas” because of their common contents and procedures. All SPCC-regulated containers, regardless of container area, are in the consolidated table in Appendix A.

Fort Belvoir has the following container areas: • Transportation Motor Pool (Building 190)• 300-Area Fuel Point (Building 324)• 300-Area Maintenance (Building 331)• 300-Area Pier (Buildings 338 and 341)• 600-Area (Building 606)• Recycling Center (Building 1089)• DPW Roads and Grounds (Building 1114)• Capitalized Fuel Station (Building 1124)• Building 1128• AAFES Gas Station – South (Building 1135)• Power Plant (Building 1234)• Motor Pool (Buildings 1417, 1419, and 1420)• Autocraft (Building 1462)• Marina (Building 1696)• Motor Pool (Buildings 1906 and 1956)• Motor Pool (Buildings 1949 and 1950)• AAFES Gas Station – North (Building 2304)• Earth Satellite (Building 2310)• INSCOM (Building 2444)• DLA (Building 2462)• HECSA (Building 2580)• 2800-Area (Buildings 2800 and 2803)• 2800-Area (Building 2838)• Golf Course (Building 2909, 2990, and 2993)• DAAF Hangar (Building 3121)• DAAF Hangars (Buildings 3140 and 3144)• DAAF Hangars (Buildings 3151 and 3153)• DAAF Fuel Point (Building 3161)• DAAF Hangars (Buildings 3231 and 3232)• NGA (Buildings 5103 and 5104)• Tulley Gate (Building 9500)


5-2

• Electrical Transformers• Emergency Generators• Heating Oil Tanks• Used Food Grease Containers

The term “visual” is used in tables throughout Section 5 to describe a method of overfill prevention wherein the person filling a container can see the level of product in the container while it is being filled and can immediately shut off inflow upon reaching 90% of container capacity [40 CFR 112.8(8)(iii-iv)].


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5.1 Transportation Motor Pool (Building 190)

5.1.1 Area Description

The Transportation Motor Pool (TMP) is the site of government vehicle maintenance. A 500-gallon AST is used to collect used oil. Various oils are dispensed for maintenance in the service bays while used POL products are collected in drums. New POL products are stored in 55-gallon drums in containment pallets outside the building. Table 5.1.1 provides container details, and Figure 5.1.1 shows their locations.

Table 5.1.1 Transportation Motor Pool Shop Containers

Container ID Type

Capacity (Gallons)

Material of Construction

Product Stored

190 AST, Horizontal 500 Steel Used Oil

190DRA 55-Gallon Drums 55 (up to 6) Steel

Oil, Hydraulic Oil,

Used Oil, Used Fuel Antifreeze,

Used Antifreeze

190DRB 55-Gallon Drums 55 (up to 12) Steel

Oil, Hydraulic Oil

Antifreeze

- Does not contain oil, not regulated by 40 CFR 112

5.1.2 Product Handling

Mechanics drain fluids from vehicles into drip pans and then hand carry the drip pans to drums inside the maintenance bay. The used oil drum is moved outside to the AST and then an electric pump is used to transfer from the drum to the tank. The used antifreeze drums are removed when full. Table 5.1.2 provides product handling details.

Table 5.1.2 Transportation Motor Pool Product Handling

Container ID Loading Method Overfill Protection Unloading Method 190 Electric Pump Sight Gauge Vacuum Truck

190DRA (New) NA NA Dispensed for Maintenance

190DRA (Used) Manual Visual Electric Pump 190DRB NA NA NA


5-4

Figure 5.1.1 Transportation Motor Pool (Building 190)


5-5

5.1.3 Secondary Containment

The AST is a double-walled steel tank. The 190DRA drums inside the building are on containment pallets. The 190DRB drums outside the building are in roll top secondary containment pallets.

Table 5.1.3 Transportation Motor Pool Secondary Containment

Container ID Type Storm Water Release 190 Double-walled NA

190DRA Containment Pallets NA 190DRB Containment Pallets NA

5.1.4 Inspection and Testing

Records of monthly visual inspections and overfill protection system tests are maintained by area personnel for at least three years. Sections 4.8 and 4.9 establish the Fort Belvoir policies for the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity and portable containers.

5.1.5 Potential Spill Scenarios

Complete container failure of AST 190 could result in a spill of up to 500 gallons of used oil. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil. Any spill from this area would flow north across asphalt to a storm water inlet and then northwest to an unnamed creek to Accotink Bay (see Figures 5.1.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.


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Table 5.1.4 Transportation Motor Pool Potential Spill Scenarios

Container ID

Spill Amount (Gallons) Contents Cause Pathway

190

500

Used Oil

Container Failure

North to drop inlet and then northwest in pipes to Accotink

Bay

5 Transfer Error

2,000 Collection Truck Error

190DRA

55 Oil,

Hydraulic Oil,

Used Oil, Used Fuel

Container Failure

5 Dispensing/Transfer Error

Antifreeze, Used

Antifreeze

190DRB 55

Oil, Hydraulic

Oil Container Failure

Antifreeze



5-7

5.2 300-Area Fuel Point (Building 324)


The 300-Area fuel point is actually an office building which also has a government fuel dispensing operation. ASTs 324R and 324T are a split tank within a shared outer shell. A 250-gallon AST is used to collect used oil. Table 5.2.1 provides container details, and Figure 5.2.1 shows their locations.

Table 5.2.1 300-Area Fuel Point Containers

Container ID Type

Capacity (Gallons)


Product Stored

324R AST, Horizontal 2,000 Steel Diesel 324S AST, Horizontal 250 Steel Used Oil 324T AST, Horizontal 2,000 Steel Diesel 324V AST, Horizontal 150 Steel Diesel


Personnel drain used oil from maintenance into AST 324S. Used oil is removed for recycling by a vacuum truck. Fuel is delivered by contractor truck. Fuel is dispensed to vehicles from ASTs 324R and 324T. Table 5.2.2 provides product handling details.

Table 5.2.2 300-Area Fuel Point Product Handling

Container ID Loading Method Overfill Protection Unloading Method 324R Truck Sight Gauge Dispensed to

Vehicles 324S Manual Sight Gauge Vacuum Truck 324T Truck Sight Gauge Dispensed to

Vehicles 324V Truck Sight Gauge Used in Generator


5-8

Figure 5.2.1 300-Area Fuel Point (Building 324)


5-9


The ASTs are double-walled, except for 324V. AST 324V has a steel dike but it is too small to contain the entire volume of the tank (See Section 6.0, Corrective Actions). Appendix D contains volume calculations for containers within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.2.3 300-Area Fuel Point Secondary Containment

Container ID Type Storm Water Release 324R Double-walled NA 324S Double-walled NA 324T Double-walled NA 324V Steel Dike Manual


Records of monthly visual inspections and overfill protection system tests are maintained by area personnel for at least three years. Section 4.8 establishes the Fort Belvoir policy for the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity.


Complete container failure of an AST could result in a spill of up to 2,000 gallons. An error dispensing fuel could spill 25 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. The loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil. Any spill from AST 324R, 324S, or 324T would flow south to a storm water inlet and then to an unnamed creek to the Potomac River (see Figures 5.2.1, 2.1, and 2.7). A spill from 324V would flow in natural drainage to an unnamed creek to the Potomac River. A spill in this area would trigger the spill response procedures listed in Section 4.7.


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Table 5.2.4 300-Area Fuel Point Potential Spill Scenarios

Container ID


324R

2,000

Diesel

Container Failure Southwest to drop inlet and then south in pipes to Potomac

River

25 Dispensing Error

3,000 Delivery Truck Error

324S

55

Used Oil


River

5 Transfer Error

2,000 Collection Truck Error

324T

2,000

Diesel


River

25 Dispensing Error


324V 150

Diesel Container Failure Southeast in open

natural drainage south to Potomac

River 3,000 Delivery Truck Error


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5.3 300-Area Maintenance (Building 331)


Building 331 is used for various types of maintenance. A 550-gallon AST contains heating oil. Various oils are dispensed for maintenance while used oil products are collected in drums. New oils are stored in 55-gallon drums inside the building. Table 5.3.1 provides container details, and Figure 5.3.1 shows their locations.

Table 5.3.1 300-Area Maintenance Shop Containers

Container ID Type

Capacity (Gallons)


Product Stored

331B AST, Horizontal 550 Steel Heating Oil

331DRA 55-Gallon Drums 55 (up to 6) Steel Used Oil

331DRB 55-Gallon Drums 55 (up to 8) Steel Oil,

Hydraulic Oil


Heating oil is delivered by contractor truck. The AST does not have a level gauge to prevent overfills and it is partially buried by accumulated soil around its base (see Corrective Actions, Section 6.0). Mechanics drain fluids from vehicles into drip pans and then hand carry the drip pans to drums. The used oil drums are emptied by a vacuum truck. Gravity spigots or hand pumps are used to dispense new oils. Table 5.3.2 provides product handling details.

Table 5.3.2 300-Area Maintenance Product Handling

Container ID Loading Method Overfill Protection Unloading Method 331B Truck Sight Gauge Used in Heater

331DRA Manual Visual Electric Pump

331DRB NA NA Dispensed for Maintenance


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Figure 5.3.1 300-Area Maintenance (Building 331)


5-13


The AST is a single-walled steel tank with no secondary containment (see Corrective Actions, Section 6.0). The drums inside the building are on containment pallets or in a shared metal dike area. Appendix D contains volume calculations for containers within diked areas.

Table 5.3.3 300-Area Maintenance Secondary Containment

Container ID Type Storm Water Release 331B None NA

331DRA Containment Pallets NA 331DRB Steel Dike NA (indoors)




Complete container failure of AST 331B could result in a spill of up to 550 gallons. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. The loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil. Any spill from this area would flow southwest to a storm water inlet and then to an unnamed creek south to the Potomac River (see Figures 5.3.1, 2.1, and 2.7). A spill in this area would trigger the spill response procedures listed in Section 4.7.


5-14

Table 5.3.4 300-Area Maintenance Potential Spill Scenarios

Container ID


331B 550

Heating Oil Container Failure Southwest and then

south to Potomac River 3,000 Delivery Truck Error

331DRA

55

Used Oil

Container Failure

Southwest and then south to Potomac

River

5 Transfer Error

3,000 Vacuum Truck Error

331DRB 55 Oil,

Hydraulic Oil

Container Failure

5 Dispensing Error


5-15

5.4 300-Area Pier (Buildings 338 and 341)


Building 338 is used for various types of maintenance related to the pier and watercraft. Building 341 is the land vehicle maintenance and administrative building. Various oils are dispensed for maintenance while used oil is collected in an AST and drums. Table 5.4.1 provides container details, and Figure 5.4.1 shows their locations.

Table 5.4.1 300-Area Pier Containers

Container ID Type

Capacity (Gallons)


Product Stored

338B AST, Horizontal 300 Steel Gasoline

338C AST, Horizontal 2,000 Steel Oily Bilge Water

338D AST, Horizontal 500 Steel Used Oil 338M Mobile Refueler 2,500 Steel Gasoline

338DRA 55-Gallon Drums 55 (up to 4) Steel Oil


Hydraulic Oil 341 AST, Horizontal 150 Steel Diesel

341DR 55-Gallon Drums 55 (up to 4) Steel Used Oil


Gasoline is transported and stored at the site by a tanker truck. The truck fills a smaller AST for use dispensing on the pier. Contractor delivery trucks fill the diesel tank. Mechanics drain fluids from vehicles into drip pans and then hand carry the drip pans to AST 338D. The used oil tank is emptied by a vacuum truck. Hand pumps are used to dispense new oils. The oily bilge water tank is intended to be used within 6 months as a container for oily bilge water cleaned out of watercraft. Table 5.4.2 provides product handling details.


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Table 5.4.2 300-Area Pier Product Handling

Container ID Loading Method Overfill Protection Unloading Method 338B Truck (338M) Sight Gauge Used in Heater 338C Manual Sight Gauge Vacuum Truck 338D Manual Sight Gauge Vacuum Truck 338M Fuel Point Automatic Gauge Dispensed to 338B

338DRA NA NA Dispensed for Maintenance


341 Truck Sight Gauge Used in Generator 341DR Manual Visual Vacuum Truck


5-17

Figure 5.4.1 300-Area Pier (Buildings 338 and 341)


5-18


AST 338C is a single-walled steel tank with a steel secondary containment dike but the containment has holes in it that must be repaired prior to using the tank (see Corrective Actions, Section 6.0). The other ASTs are double-walled. The drums are on containment pallets in a shed or in a steel containment conex. The tanker truck is parked in a plastic containment dike with walls that fold down for driving in and out. Appendix D contains volume calculations for containers within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.4.3 300-Area Pier Secondary Containment

Container ID Type Storm Water Release 338B Double-Walled NA 338C Steel Dike Manual 338D Double-Walled NA 338M Plastic Dike Manual

338DRA Containment Pallets NA 338DRB Steel Conex NA

341 Double-Walled NA 341DR Containment Pallets NA




Complete container failure of AST 338B could result in a spill of up to 300 gallons. It is assumed that only one drum would spill in a given event. An error dispensing fuel could spill 25 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 2,500 gallons. The loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil. Any spill from this area would flow south to the Potomac River (see Figures 5.4.1, 2.1, and 2.7). A spill in this area would trigger the spill response procedures listed in Section 4.7.


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Table 5.4.4 300-Area Pier Potential Spill Scenarios

Container ID


338B

300

Gasoline

Container Failure

South directly to Potomac River

25 Transfer Error


338C

2,000 Oily Bilge

Water

Container Failure

25 Transfer Error


338D

500

Used Oil

Container Failure

5 Transfer Error


338M 2,500 Gasoline Container Failure

338DRA 55



5 Dispensing Error

338DRB 55 Oil,

Hydraulic Oil

Container Failure

5 Dispensing Error

341 150

Diesel Container Failure



341DR

55

Used Oil

Container Failure

5 Transfer Error



5-20

5.5 600-Area (Building 606)


Building 606 is a small wastewater pump station. The rest of the 600-Area includes a bulk waste drop off site and a contractor fueling point. Table 5.5.1 provides container details, and Figure 5.5.1 shows their locations.

Table 5.5.1 600-Area Containers

Container ID Type

Capacity (Gallons)


Product Stored

600 AST, Horizontal 500 Steel Diesel 606A AST, Horizontal 250 Steel Diesel 606B AST, Horizontal 500 Steel Diesel


Contractor delivery trucks fill the diesel tanks. Diesel is dispensed into vehicles/equipment. ASTs 600 and 606B do not have level gauges (see Corrective Actions, Section 6.0). Table 5.5.2 provides product handling details.

Table 5.5.2 600-Area Product Handling

Container ID Loading Method Overfill Protection Unloading Method

600 Truck None Dispensed to Vehicles

606A Truck Sight Gauge Used in Generator

606B Truck None Dispensed to Vehicles


5-21

Figure 5.5.1 600-Area (Building 606)


5-22


AST 606B is a single-walled steel tank with a plastic secondary containment dike. The other ASTs are double-walled. Appendix D contains volume calculations for containers within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.5.3 600-Area Secondary Containment

Container ID Type Storm Water Release 600 Double-Walled NA

606A Double-Walled NA 606B Plastic Dike Manual




Complete container failure of an AST could result in a spill of up to 500 gallons. An error dispensing fuel could spill 25 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow south in open natural drainage to an unnamed creek south to the Potomac River (see Figures 5.5.1, 2.1, and 2.7). A spill in this area would trigger the spill response procedures listed in Section 4.7.


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Table 5.5.4 600-Area Potential Spill Scenarios

Container ID


600

500

Diesel

Container Failure South in open

natural drainage to Potomac River

25 Dispensing Error


606A 250


South in open natural drainage to

Potomac River


606B

500

Diesel

Container Failure

25 Dispensing Error



5-24

5.6 Recycling Center (Building 1089)


Building 1089 is the recycling center. Used oil from customers is collected in an AST. Table 5.6.1 provides container details, and Figure 5.6.1 shows their locations.

Table 5.6.1 Recycling Center Containers

Container ID Type

Capacity (Gallons)


Product Stored



On-post residents pour used oil in the AST. The used oil tank is emptied by a vacuum truck. Table 5.4.2 provides product handling details.

Table 5.6.2 Recycling Center Product Handling

Container ID Loading Method Overfill Protection Unloading Method 1089 Manual Sight Gauge Vacuum Truck


AST 1089 is double-walled and does not collect storm water.

Table 5.6.3 Recycling Center Secondary Containment



5-25

Figure 5.6.1 Recycling Center (Building 1089)


5-26




Complete container failure of the AST could result in a spill of up to 500 gallons. The loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil. Any spill from this area would flow northwest in open drainage to Accotink Bay (see Figures 5.6.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.6.4 Recycling Center (Building 1089) Potential Spill Scenarios

Container ID


1089

500

Used Oil

Container Failure Northwest in open

drainage to Accotink Bay

5 Transfer Error



5-27

5.7 DPW Roads and Grounds (Building 1114)


Building 1114 is used as the roads and grounds office and fuel point. Table 5.7.1 provides container details, and Figure 5.7.1 shows their locations.

Table 5.7.1 DPW Roads and Grounds Containers

Container ID Type

Capacity (Gallons)


Product Stored

1109C AST, Horizontal 500 Steel Kerosene 1109D AST, Horizontal 500 Steel Diesel 1109E AST, Horizontal 500 Steel Diesel 1114A AST, Horizontal 5,000 Steel Gasoline


Contractor delivery trucks fill the fuel tanks. Fuel is dispensed into vehicles/equipment. Kerosene is dispensed for use in space heaters at entrance gates. ASTs 1109D and 1109E do not have level gauges (see Corrective Actions, Section 6.0). Table 5.7.2 provides product handling details.

Table 5.7.2 DPW Roads and Grounds Product Handling


1109C Truck Sight Gauge Dispensed to Heaters

1109D Truck None Dispensed to Vehicles

1109E Truck None Dispensed to Vehicles

1114A Truck Sight Gauge Dispensed to Vehicles


5-28

Figure 5.7.1 DPW Roads and Grounds (Building 1114)


5-29


AST 1109D is single-walled with a plastic containment dike. The other ASTs are double-walled. Appendix D contains volume calculations for containers within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.7.3 DPW Roads and Grounds Secondary Containment

Container ID Type Storm Water Release 1109C Double-Walled NA 1109D Plastic Dike Manual 1109E Double-Walled NA 1114A Double-Walled NA




Complete container failure of an AST could result in a spill of up to 5,000 gallons. An error dispensing fuel could spill 25 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow north in open drainage to an unnamed creek west to Accotink Bay (see Figures 5.7.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.


5-30

Table 5.7.4 DPW Roads and Grounds Potential Spill Scenarios

Container ID


1109C

500

Kerosene

Container Failure

North in open drainage and then west to Accotink

Bay

25 Dispensing Error


1109D

500

Diesel

Container Failure

25 Dispensing Error


1109E

500

Diesel

Container Failure

25 Dispensing Error


1114A

5,000

Gasoline

Container Failure

25 Dispensing Error



5-31

5.8 Capitalized Fuel Station (Building 1124)


Building 1124 is the main fuel point for Fort Belvoir government vehicles. There are four USTs at the site. Two USTs hold fuel for vehicles, one holds used oil, and one is empty and temporarily out-of-service. Table 5.8.1 provides container details, and Figure 5.8.1 shows their locations.

Table 5.8.1 Capitalized Fuel Station Containers

Container ID Type

Capacity (Gallons)


Product Stored

1124C* UST* 12,000* Steel* E85

(Ethanol / Gasoline)*

1124D UST 12,000 Steel Used Oil

1124H UST 30,000 Fiberglass Reinforced

Plastic (FRP) Gasoline

1124I UST 30,000 FRP Diesel * - empty and temporarily out-of-service


Contractor delivery trucks fill the UST fuel tanks. Fuel is dispensed into vehicles/equipment and also through the loading rack into mobile refuelers. The used oil UST is filled from an oil/water separator that collects used oil from throughout the installation. A vacuum truck empties the used oil UST. Table 5.8.2 provides product handling details.

Table 5.8.2 Capitalized Fuel Station Product Handling


1124C* Truck* Automatic Tank Gauging*

Dispensed to Vehicles*

1124D From O/W Separator Automatic Tank Gauging Vacuum Truck

1124H Truck Automatic Tank Gauging Dispensed to Vehicles

1124I Truck Automatic Tank Gauging Dispensed to Vehicles


5-32

Figure 5.8.1 Capitalized Fuel Station (Building 1124)


5-33


The USTs do not have to meet SPCC Plan requirements for secondary containment. The loading/unloading rack has a concrete berm and a concrete holding basin with a valve to release storm water. The loading/unloading rack containment volume calculation is in Appendix D.

Table 5.8.3 Capitalized Fuel Station Secondary Containment

Container ID Type Storm Water Release 1124 Rack Concrete Holding Basin Manual


Inspection and testing requirements from 40 CFR 280 are not included in this SPCC Plan.


An error dispensing fuel could spill 25 gallons. The loss of the entire contents of a larger fuel delivery tanker truck or a fuel truck being filled at the loading/unloading rack could spill 5,000 gallons. Any spill from this area would flow north across asphalt to a storm water inlet and then to an unnamed creek west to Accotink Bay (see Figures 5.8.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.8.4 DPW Roads and Grounds Potential Spill Scenarios

Container ID


1124C*

25

E85* (empty)

Dispensing Error North and then

west to Accotink Bay

3,000 Error Unloading to Mobile Refueler


1124D 3,000 Used Oil Vacuum Truck Error

North and then west to Accotink

Bay 1124H

25

Gasoline

Dispensing Error




5-34

Container ID


1124I

25

Diesel

Dispensing Error



* - empty and temporarily out-of-service


5-35

5.9 Building 1128


Building 1128 has a diesel AST. Table 5.9.1 provides container details, and Figure 5.9.1 shows their locations.

Table 5.9.1 Building 1128 Containers

Container ID Type

Capacity (Gallons)


Product Stored

1128 AST, Horizontal 500 Steel Diesel


Contractor delivery trucks fill the fuel tank. Fuel is dispensed into vehicles/equipment. Table 5.9.2 provides product handling details.

Table 5.9.2 Building 1128 Product Handling


1128 Truck Sight Gauge Dispensed to Heaters


The AST is double-walled and does not collect storm water.

Table 5.9.3 Building 1128 Secondary Containment



5-36

Figure 5.9.1 Building 1128


5-37




Complete container failure of an AST could result in a spill of up to 500 gallons. An error dispensing fuel could spill 25 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow west in open drainage to Accotink Bay (see Figures 5.9.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.9.4 Building 1128 Potential Spill Scenarios

Container ID


1128

500

Diesel

Container Failure West in open drainage to

Accotink Bay 25 Dispensing Error



5-38

5.10 AAFES Gas Station - South (Building 1135)


Building 1135 is a gas station for privately owned vehicles. Three USTs hold fuel for vehicles. There is also a food grease container at the site (see Section 5.35). Table 5.10.1 provides container details, and Figure 5.10.1 shows their locations.

Table 5.10.1 AAFES Gas Station Containers

Container ID Type

Capacity (Gallons)


Product Stored

1135A UST 20,000 FRP Gasoline 1135B UST 10,000 FRP Gasoline 1135C UST 10,000 FRP Gasoline


Contractor delivery trucks fill the USTs. Fuel is dispensed into vehicles through standard commercial pumps. Table 5.10.2 provides product handling details.

Table 5.10.2 AAFES Gas Station Product Handling


1135A Truck Automatic Tank Gauging Dispensed to Vehicles

1135B Truck Automatic Tank Gauging Dispensed to Vehicles

1135C Truck Automatic Tank Gauging Dispensed to Vehicles


5-39

Figure 5.10.1 AAFES Gas Station (Building 1135)


5-40


The USTs do not have to meet SPCC Plan requirements for secondary containment.




An error dispensing fuel could spill 25 gallons. The loss of the entire contents of a larger fuel delivery tanker truck could spill 5,000 gallons. Any spill from this area would flow across the parking lot north to a storm water inlet and then northwest to Accotink Bay (see Figures 5.10.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.10.3 AAFES Gas Station Potential Spill Scenarios

Container ID


1135A 25

Gasoline Dispensing Error

North and then northwest to Accotink Bay


1135B 25



1135C 25




5-41

5.11 Power Plant (Building 1234)


Building 1234 is the central utility plant for the hospital. There are five buried tanks that store fuel onsite. Three of the tanks are 40 CFR 280 regulated USTs because they fuel electrical generators (See Appendix A, Table 2). Two of the tanks are 40 CFR 112 regulated because they store heating oil for consumptive use on the premises. Each generator also has a day tank aboveground inside the building. There are also chemical containers used to treat water used in heating systems. Table 5.11.1 provides container details, and Figure 5.11.1 shows their locations.

Table 5.11.1 Power Plant Containers

Container ID Type

Capacity (Gallons)


Product Stored

1234E AST, Horizontal 600 Steel Diesel 1234F AST, Horizontal 600 Steel Diesel 1234G AST, Horizontal 600 Steel Diesel 1234H AST, Horizontal 600 Steel Diesel

1234I AST, Horizontal 125 Plastic Sodium Hydroxide

1234DRA 65-Gallon Drum 65 Plastic Sodium Hypochlorite

1234DRB 55-Gallon Drums 55 (up to 4) Plastic

Sodium Hydroxide, Diethanol-

Amine 1250U Buried Tank 20,000 FRP Heating Oil 1251U Buried Tank 20,000 FRP Heating Oil 1252A UST 20,000 FRP Diesel 1253A UST 20,000 FRP Diesel 1254A UST 20,000 FRP Diesel



Contractor delivery trucks fill the USTs and buried heating oil tanks. Diesel is pumped into either the generator day tanks or the boilers. The chemical containers are filled by hand from small containers and the chemicals are fed into the water treatment system. Table 5.11.2 provides product handling details.


5-42

Table 5.11.2 Power Plant Product Handling Container ID Loading Method Overfill Protection Unloading Method

1234E Pumped from USTs Overfill Alarm Used in Generators

1234F Pumped from USTs Overfill Alarm Used in Generators

1234G Pumped from USTs Overfill Alarm Used in Generators

1234H Pumped from USTs Overfill Alarm Used in Generators

1234I Manual Visual Used in Water Treatment

1234DRA Manual Visual Used in Water Treatment

1234DRB Manual Visual Used in Water Treatment

1250U Truck Automatic Tank Gauging Used in Boiler 1251U Truck Automatic Tank Gauging Used in Boiler



The day tank ASTs are double-walled and do not collect storm water. The chemical containers do not have secondary containment (see Corrective Actions, Section 6.0). The buried heating oil tanks are double-walled.

Table 5.11.3 Power Plant Secondary Containment

Container ID Type Storm Water Release 1234E Double-Walled NA 1234F Double-Walled NA 1234G Double-Walled NA 1234H Double-Walled NA 1234I None NA

1234DRA None NA 1234DRB None NA

1250U Double-Walled NA 1251U Double-Walled NA


5-43

Figure 5.11.1 Power Plant (Building 1234)


5-44




Complete container failure of an AST could result in a spill of up to 600 gallons. An error transferring chemicals could spill 5 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow west across the concrete to a storm water inlet and then south to an unnamed creek west to Accotink Bay (see Figures 5.11.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.11.4 Power Plant Potential Spill Scenarios

Container ID


1234E 600 Diesel Container Failure West across

concrete and then south to Accotink

Bay

1234F 600 Diesel Container Failure

1234G 600 Diesel Container Failure

1234H 600 Diesel Container Failure

1234I 125 Sodium

Hydroxide Container Failure

West across concrete and then south to Accotink

Bay

5 Transfer Error

1234DRA 65 Sodium

Hypochlorite Container Failure

5 Transfer Error

1234DRB 55 Sodium

Hydroxide, Diethanol-

Amine

Container Failure

5 Transfer Error

1250U 20,000

Heating Oil Container Failure

West across concrete and then south to Accotink

Bay


1251U 20,000




5-45

Container ID


1252A 3,000 Diesel Delivery Truck Error West across concrete and then south to Accotink

Bay

1253A 3,000 Diesel Delivery Truck Error

1254A 3,000 Diesel Delivery Truck Error



5-46

5.12 Motor Pool (Buildings 1417, 1419, and 1420)


This area is used for two separate vehicle maintenance organizations: military motor pool with portable generators and the DPW motor pool. There are five ASTs and two drum storage areas outside the building in the parking area to the north. Other ASTs and drum storage areas are inside the buildings. Table 5.12.1 provides container details, and Figure 5.12.1 shows their locations.

Table 5.12.1 Motor Pool Containers

Container ID Type

Capacity (Gallons)


Product Stored

1417H AST, Horizontal 500 Steel Oil 1417I AST, Horizontal 500 Steel Oil 1417J AST, Horizontal 500 Steel Hydraulic Oil 1417K AST, Horizontal 500 Steel Used Oil 1417L AST, Horizontal 600 Steel Diesel 1417M AST, Horizontal 600 Steel Diesel


Oil, Hydraulic Oil

Antifreeze


Oil, Hydraulic Oil

Antifreeze

1417DRC 55-Gallon Drums 55 (up to 8) Steel

Oil, Hydraulic Oil

Antifreeze

1417DRD 55-Gallon Drums 55 (up to 4) Steel

Used Oil, Used Fuel

Used Antifreeze

1420A AST, Horizontal 250 Steel Hydraulic Oil 1420B AST, Horizontal 275 Steel Used Oil 1420C AST, Horizontal 275 Steel Oil


Used Oil Used

Antifreeze


5-47


Oil, Hydraulic Oil,

Grease Antifreeze



Contractor delivery trucks fill the diesel tanks. The two diesel tanks do not have level gauges to prevent overfills (See Corrective Actions, Section 6.0). Diesel is dispensed into vehicles or generators (for testing in the parking area). The oil tanks are filled from drums by small electric pumps. Oil is dispensed by hand pump or gravity spigots. Collection drums and tanks are filled by manually pouring used products. The collection drums and tanks are emptied via vacuum truck. Table 5.12.2 provides product handling details.

Table 5.12.2 Motor Pool Product Handling


1417H Pumped from Drums Sight Gauge Dispensed for

Maintenance

1417I Pumped from Drums Sight Gauge Dispensed for

Maintenance

1417J Pumped from Drums Sight Gauge Dispensed for

Maintenance 1417K Manual Sight Gauge Vacuum Truck

1417L Truck None Dispensed to Vehicles

1417M Truck None Used in Generators 1417DRA NA NA Pumped into ASTs 1417DRB NA NA Pumped into ASTs

1417DRC NA NA Dispensed for Maintenance

1417DRD Manual Visual Vacuum Truck

1420A Pumped from Drums Sight Gauge Dispensed for

Maintenance 1420B Manual Sight Gauge Vacuum Truck

1420C Pumped from Drums Sight Gauge Dispensed for

Maintenance


5-48

1420DRA Manual Visual Vacuum Truck




The oil ASTs are double-walled and do not collect storm water. The drums are in steel conexes, on containment pallets, or in a concrete dike indoors. The ASTs at Building 1420 share an indoor concrete containment dike. One diesel tank does not have secondary containment (see Corrective Actions, Section6.0) while the other uses a temporary plastic dike. Appendix D contains volume calculations for containers within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.12.3 Motor Pool Secondary Containment

Container ID Type Storm Water Release 1417H Double-Walled NA 1417I Double-Walled NA 1417J Double-Walled NA 1417K Double-Walled NA 1417L None NA 1417M Plastic Dike Manual

1417DRA Steel Conex NA 1417DRB Steel Conex NA 1417DRC Plastic Containment Pallet NA 1417DRD Plastic Containment Pallet NA

1420A Concrete Dike NA (indoors) 1420B Concrete Dike NA (indoors) 1420C Concrete Dike NA (indoors)

1420DRA Plastic Dike NA 1420DRB Concrete Dike NA (indoors)



5-49

Figure 5.12.1 Motor Pool (Buildings 1417, 1419, and 1420)


5-50




Complete container failure of an AST could result in a spill of up to 600 gallons. An error transferring in or out of drums could spill 5 gallons. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. The loss of the entire contents of the vacuum collection truck could spill 2,000 gallons. Spills from the 1417 area would flow across the parking lot to a storm water inlet and then west to Accotink Creek; while spills from the 1419 and 1420 areas would flow south to a storm water inlet and then south to Accotink Bay (see Figures 5.12.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.12.4 Motor Pool Potential Spill Scenarios

Container ID


1417H

500

Oil

Container Failure

West to Accotink Creek

5 Dispensing Error

5 Transfer Error

1417I

500

Oil

Container Failure

5 Dispensing Error

5 Transfer Error

1417J

500

Hydraulic Oil

Container Failure

5 Dispensing Error

5 Transfer Error

1417K

500

Used Oil

Container Failure

5 Transfer Error

2,000 Vacuum Truck


5-51

Container ID


Error

1417L

600

Diesel

Container Failure


25 Dispensing Error


1417M

600

Diesel

Container Failure

25 Dispensing Error


1417DRA 55 Oil,

Hydraulic Oil Container FailureWest to Accotink

Creek Antifreeze

1417DRB 55 Oil,

Hydraulic Oil Container FailureAntifreeze

1417DRC 55 Oil,

Hydraulic Oil Container Failure

South to Accotink Bay 5 Dispensing Error

Antifreeze

1417DRD

55 Used Oil, Used Fuel

Container Failure South to Accotink

Bay 5 Transfer Error Used Antifreeze

1420A

250

Hydraulic Oil

Container Failure

South to Accotink Bay

5 Dispensing Error

5 Transfer Error

1420B

275

Used Oil

Container Failure

5 Transfer Error


1420C 275 Oil Container Failure


5-52

Container ID


5 Dispensing Error

5 Transfer Error

1420DRA

55 Used Oil

Container Failure

South to Accotink Bay

5 Transfer Error Used Antifreeze

1420DRB

55 Oil, Hydraulic

Oil, Grease

Container Failure

5 Dispensing Error Antifreeze



5-53

5.13 Autocraft (Building 1462)


The Autocraft Shop is used by customers to complete their personal vehicle maintenance. There are two ASTs outside the building and a drum storage area inside. Table 5.13.1 provides container details, and Figure 5.13.1 shows their locations.

Table 5.13.1 Autocraft Containers

Container ID Type

Capacity (Gallons)


Product Stored

1462B AST, Horizontal 250 Steel Used Antifreeze

1462C AST, Horizontal 500 Steel Used Oil




Collection drums and tanks are filled by manually pouring used products. Used oil is also transferred into the AST from drums by a small pump. The collection tanks are emptied via vacuum truck. Table 5.13.2 provides product handling details.

Table 5.13.2 Autocraft Product Handling

Container ID Loading Method Overfill Protection Unloading Method 1462B Manual Sight Gauge Vacuum Truck

1462C Pumped from Drums Sight Gauge Vacuum Truck

1462DR Manual Visual Pumped into AST



The ASTs are double-walled and do not collect storm water. The drums are on a steel containment pallet indoors.


5-54

Figure 5.13.1 Autocraft (Building 1462)


5-55

Table 5.13.3 Autocraft Secondary Containment

Container ID Type Storm Water Release 1462B Double-Walled NA 1462C Double-Walled NA

1462DR Steel Containment Pallet NA





Complete container failure of an AST could result in a spill of up to 500 gallons. An error transferring in or out of drums could spill 5 gallons. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the vacuum collection truck could spill 2,000 gallons. Any spill from this area would flow to a storm water inlet and then west to an unnamed creek west to Accotink Creek (see Figures 5.13.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.13.4 Autocraft Potential Spill Scenarios

Container ID


1462B

250

Used Antifreeze

Container Failure


5 Transfer Error


1462C

500

Used Oil

Container Failure

5 Transfer Error



5-56

Container ID


1462DR 55

Used Oil Container Failure

5 Dispensing Error



5-57

5.14 Marina (Building 1696)


The Marina is used by customers to complete their personal boat maintenance. There is an AST for an emergency generator and a buried heating oil tank for the building. The buried heating oil tank is less than 50 yards from the shoreline. Table 5.14.1 provides container details, and Figure 5.14.1 shows their locations.

Table 5.14.1 Marina Containers

Container ID Type

Capacity (Gallons)


Product Stored

1695 AST, Horizontal 250 Steel Diesel 1696CU Buried Tank 1,000 FRP Heating Oil


Contractor delivery trucks fill the diesel and heating oil tanks. Table 5.14.2 provides product handling details.

Table 5.14.2 Marina Product Handling

Container ID Loading Method Overfill Protection Unloading Method 1695 Truck Sight Gauge Used in Generator

1696CU Truck Overfill Alarm Used in Heater


The AST and buried tank are double-walled and do not collect storm water.

Table 5.14.3 Marina Secondary Containment


1696CU Double-Walled NA


5-58

Figure 5.14.1 Marina (Building 1696)


5-59


Records of monthly visual inspections and overfill protection system tests are maintained by area personnel for at least three years. Section 4.8 establishes the Fort Belvoir policy for the integrity testing of shop-built containers (and piping) with less than 5,000 gallons capacity.


Complete container failure of the AST could result in a spill of up to 250 gallons. A leak of the buried tank could release 1,000 gallons. The fuel delivery truck could spill 3,000 gallons. Any spill from this area would flow west directly to Dogue Creek (see Figures 5.14.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.14.4 Marina Potential Spill Scenarios

Container ID


1695 250


West to Dogue Creek


1696CU 1,000




5-60

5.15 Motor Pool (Buildings 1906 and 1956)


This area is used for two separate vehicle maintenance organizations: a military motor pool with portable generators and an unoccupied motor pool. There are four ASTs and three drum storage areas outside the buildings. Table 5.15.1 provides container details, and Figure 5.15.1 shows their locations.


Container ID Type

Capacity (Gallons)


Product Stored

1906C AST, Horizontal 500 Steel Used Oil 1906E AST, Horizontal 500 Steel Heating Oil 1956A AST, Horizontal 500 Steel Used Oil 1956B AST, Horizontal 2,000 Steel Diesel


Used Oil Used

Antifreeze


Oil, Hydraulic Oil

Antifreeze

1956DRC 55-Gallon Drums 55 (up to 4) Steel

Oil, Hydraulic Oil

Antifreeze - Does not contain oil, not regulated by 40 CFR 112


Contractor delivery trucks fill the diesel tank. Diesel is dispensed into vehicles or generators (for testing in the parking area). Oil is dispensed by hand pump or gravity spigots. The used oil tanks are filled by manually pouring used products. AST 1906C does not have a level gauge to prevent overfills (see Corrective Actions, Section 6.0). The collection drums and tanks are emptied via vacuum truck. Table 5.15.2 provides product handling details.


5-61


Container ID Loading Method Overfill Protection Unloading Method 1906C Manual None Vacuum Truck 1906E Truck Sight Gauge Used in Heater 1956A Manual Sight Gauge Vacuum Truck 1956B Truck Sight Gauge Used in Generators

1956DRA Manual Visual Vacuum Truck 1956DRB NA NA NA

1956DRC NA NA Dispensed for Maintenance



The ASTs are double-walled and do not collect storm water. The drums are in steel conexes or on containment pallets. The 1956DRC drums are not properly within the containment pallets, so they do not have proper secondary containment (see Corrective Actions, Section 6.0).


Container ID Type Storm Water Release 1906C Double-Walled NA 1906E Double-Walled NA 1956A Double-Walled NA 1956B Double-Walled NA

1956DRA Plastic Containment Pallet NA 1956DRB Steel Conex NA 1956DRC Plastic Containment Pallet NA



5-62

Figure 5.15.1 Motor Pool (Buildings 1906 and 1956)


5-63




Complete container failure of an AST could result in a spill of up to 2,000 gallons. An error transferring in or out of drums could spill 5 gallons. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. The loss of the entire contents of the vacuum collection truck could spill 2,000 gallons. Any spill from 1906 would flow west in storm water pipes to Accotink Creek while spills from 1956 would flow south first in open drainage flowing west to Accotink Creek (see Figures 5.15.1, 2.1, and 2.5). A spill in this area would trigger the spill response procedures listed in Section 4.7.


Container ID


1906C

500

Used Oil

Container Failure

West in pipes to Accotink Creek

5 Transfer Error


1906E 500



1956A

500

Used Oil

Container Failure

South in open drainage and then west to Accotink

Creek

5 Transfer Error


1956B

2,000

Diesel

Container Failure

25 Dispensing Error



5-64

Container ID


1956DRA 55 Used Oil

Container Failure

South in open drainage and then west to Accotink

Creek

Antifreeze Transfer Error

1956DRB 55 Oil,

Hydraulic Oil Container FailureAntifreeze

1956DRC 55 Oil,





5-65

5.16 Motor Pool (Buildings 1949 and 1950)


This area is used for two separate vehicle maintenance organizations (both military). There are two ASTs and two drum storage areas, plus a buried heating oil tank that is shared between the buildings. Table 5.16.1 provides container details, and Figure 5.16.1 shows their locations.


Container ID Type

Capacity (Gallons)


Product Stored


1949DR 55-Gallon Drums 55 (up to 4) Steel

Oil Antifreeze,

Used Antifreeze

1950AU Buried Tank 3,000 Steel Heating Oil 1950B AST, Horizontal 250 Steel Used Oil

1950DRA 55-Gallon Drums 55 (up to 2) Steel Used

Antifreeze


Oil, Hydraulic Oil

Antifreeze - Does not contain oil, not regulated by 40 CFR 112


Contractor delivery trucks fill the heating oil tank. Diesel is used in the building boilers. Oil is dispensed by hand pump or gravity spigots. The used oil tanks are filled by manually pouring used products. The collection drums and tanks are emptied via vacuum truck. Table 5.16.2 provides product handling details.


Container ID Loading Method Overfill Protection Unloading Method 1949 Manual Sight Gauge Vacuum Truck

1949DR (New) NA NA Dispensed for Maintenance

1949DR (Used) Manual Sight Gauge Vacuum Truck


5-66

1950AU Truck Sight Gauge Used in Heaters 1950B Manual Sight Gauge Vacuum Truck

1950DRA Manual Visual Vacuum Truck




AST 1949 is double-walled and does not collect storm water. AST 1950B does not have secondary containment (see Corrective Actions, Section 6.0). The drums are in steel conexes or on containment pallets.



1949DR Plastic Containment Pallet NA 1950AU Double-Walled NA 1950B None NA

1950DRA Plastic Containment Pallet NA 1950DRB Steel Conex NA



5-67

Figure 5.16.1 Motor Pool (Buildings 1949 and 1950)


5-68




Complete container failure of an AST could result in a spill of up to 250 gallons. An error transferring in or out of drums could spill 5 gallons. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. The loss of the entire contents of the vacuum collection truck could spill 2,000 gallons. Any spill from this area would flow east across the parking lot to a storm water inlet and then south and west in open drainage to Accotink Creek (see Figures 5.16.1, 2.1, and 2.5). A spill in this area would trigger the spill response procedures listed in Section 4.7.


Container ID


1949

250

Used Oil

Container Failure

East across surface and then south and

west in open drainage to

Accotink Creek

5 Transfer Error


1949DR

55 Oil

Container Failure

5 Dispensing Error

5 Antifreeze,

Used Antifreeze

Transfer Error

1950AU Heating Oil

Container Failure East across surface and then south and

west in open drainage to

Accotink Creek 3,000 Delivery Truck

Error

1950B 250

Used Oil Container Failure East across surface

and then south and west in open 5 Transfer Error


5-69

Container ID



drainage to Accotink Creek

1950DRA 55 Used

Antifreeze Container Failure

5 Transfer Error

1950DRB 55 Oil,





5-70

5.17 AAFES Gas Station - North (Building 2304)


Building 2304 is a gas station for privately owned vehicles. Four USTs hold fuel for vehicles. There is also a food grease container at the site (see Section 5.35). Table 5.17.1 provides container details, and Figure 5.17.1 shows their locations.

Table 5.17.1 AAFES Gas Station Containers

Container ID Type

Capacity (Gallons)


Product Stored

2304A UST 12,000 FRP Gasoline 2304B UST 12,000 FRP Gasoline 2304C UST 12,000 FRP Gasoline 2304D UST 12,000 FRP Gasoline


Contractor delivery trucks fill the USTs. Fuel is dispensed into vehicles through standard commercial pumps. Table 5.17.2 provides product handling details.

Table 5.17.2 AAFES Gas Station Product Handling



2304B Truck Automatic Tank Gauging Dispensed to Vehicles

2304C Truck Automatic Tank Gauging Dispensed to Vehicles

2304D Truck Automatic Tank Gauging Dispensed to Vehicles


5-71

Figure 5.17.1 AAFES Gas Station (Building 2304)


5-72


The USTs do not have to meet SPCC Plan requirements for secondary containment.




An error dispensing fuel could spill 25 gallons. The loss of the entire contents of a larger fuel delivery tanker truck could spill 5,000 gallons. Any spill from this area would flow north across the parking lot to a storm water inlet to an unnamed creek and then southwest to Accotink Creek (see Figures 5.17.1, 2.1, and 2.5). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.17.3 AAFES Gas Station Potential Spill Scenarios

Container ID


2304A 25


North across surface and then

southwest to Accotink Creek


2304B 25



2304C 25



2304D 25




5-73

5.18 Earth Satellite (Building 2310)


This area is a satellite control facility. There are ASTs that are day tanks for backup power, as well as a separate emergency generator and a drum storage area. An UST (2310A) is the main fuel storage tank (see Appendix A, Table A-2). Table 5.18.1 provides container details, and Figure 5.18.1 shows their locations.

Table 5.18.1 Earth Satellite Containers

Container ID Type

Capacity (Gallons)


Product Stored

2310A UST 25,000 FRP Diesel 2310B AST, Horizontal 500 Steel Diesel 2310C AST, Horizontal 335 Steel Diesel 2310D AST, Horizontal 335 Steel Diesel 2310E AST, Horizontal 335 Steel Diesel

2310DR 55-Gallon Drums 55 (up to 4) Steel Oil,

Used Oil


Contractor delivery trucks fill the diesel UST and tank 2310B. Oil is dispensed by hand pump or gravity spigots. The used oil drums are filled by manually pouring used products. The collection drums are emptied via vacuum truck. Table 5.18.2 provides product handling details.

Table 5.18.2 Earth Satellite Product Handling

Container ID Loading Method Overfill Protection Unloading Method 2310B Truck Sight Gauge Used in Generator 2310C Pump from UST Overfill Alarm Used in Generator 2310D Pump from UST Overfill Alarm Used in Generator 2310E Pump from UST Overfill Alarm Used in Generator

2310DR (New) NA NA Dispensed for Maintenance

2310DR (Used) Manual Visual Vacuum Truck


5-74


AST 2310B is double-walled and does not collect storm water. The day tank ASTs (2310C, 2310D, and 2310E) are inside the building but, because of penetrations through the walls/dikes, do not have secondary containment (see Corrective Actions, Section 6.0). The drums are on containment pallets inside the building.

Table 5.18.3 Earth Satellite Secondary Containment

Container ID Type Storm Water Release 2310B Double-Walled NA 2310C None NA 2310D None NA 2310E None NA

2310DR Plastic Containment Pallet NA


5-75

Figure 5.18.1 Earth Satellite (Building 2310)


5-76




Complete container failure of an AST could result in a spill of up to 500 gallons. An error transferring in or out of drums could spill 5 gallons. It is assumed that only one drum would spill in a given event. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. The loss of the entire contents of the vacuum collection truck could spill 2,000 gallons. Any spill from this area would flow north to a storm water inlet and then southeast in an unnamed creek to Dogue Creek (see Figures 5.18.1, 2.1, and 2.5). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.18.4 Earth Satellite Potential Spill Scenarios

Container ID


2310A 3,000 Diesel Delivery Truck Error North to storm

water inlet and then southeast to Dogue

Creek 2310B 500



2310C 335 Diesel Container Failure North to storm water inlet and then southeast to Dogue

Creek

2310D 335 Diesel Container Failure

2310E 335 Diesel Container Failure

2310DR

55

Oil, Used Oil

Container Failure North to storm

water inlet and then southeast to Dogue

Creek

5 Dispensing Error

5 Transfer Error



5-77

5.19 INSCOM (Building 2444)


This area is a satellite control facility. There are ASTs that are day tanks for backup power, as well as chemical tanks for boiler water treatment. An UST (2444C) is the main fuel storage tank (see Appendix A, Table A-2). Used food grease is also onsite (see Section 5.35). Table 5.19.1 provides container details, and Figure 5.19.1 shows their locations.

Table 5.19.1 INSCOM Containers

Container ID Type

Capacity (Gallons)


Product Stored

2444C UST 25,000 FRP Diesel 2444D AST, Horizontal 250 Steel Diesel 2444E AST, Horizontal 250 Steel Diesel 2444F AST, Horizontal 250 Steel Diesel

2444G AST, Vertical 100 Plastic Sodium Hydroxide

2444H AST, Vertical 100 Plastic Acetic Acid

2444I AST, Vertical 100 Plastic Sodium Hypochlorite



Contractor delivery trucks fill the diesel UST which pumps to the day tanks. Chemicals are poured into the tanks from small containers and then dispensed directly into the boiler water system. Table 5.19.2 provides product handling details.


5-78

Table 5.19.2 INSCOM Product Handling

Container ID Loading Method Overfill Protection Unloading Method 2444D Pump from UST Overfill Alarm Used in Generator 2444E Pump from UST Overfill Alarm Used in Generator 2444F Pump from UST Overfill Alarm Used in Generator

2444G Manual Visual Used in Water Treatment

2444H Manual Visual Used in Water Treatment



The day tank ASTs are double-walled and do not collect storm water. The chemical tank ASTs (2444G, 2444H, and 2444I) are inside the building, but do not have secondary containment (see Corrective Actions, Section 6.0).

Table 5.19.3 INSCOM Secondary Containment

Container ID Type Storm Water Release 2444D Double-Walled NA 2444E Double-Walled NA 2444F Double-Walled NA 2444G None NA 2444H None NA 2444I None NA



5-79

Figure 5.19.1 INSCOM (Building 2444)


5-80




Complete container failure of an AST could result in a spill of up to 250 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow south across asphalt to a storm water inlet and then south to an unnamed creek and south to Accotink Creek (see Figures 5.19.1, 2.1, and 2.5). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.19.4 INSCOM Potential Spill Scenarios

Container ID


2444D 250 Diesel Container Failure South to Accotink

Creek 2444E 250 Diesel Container Failure


2444G 55 Sodium


South to Accotink Creek

5 Transfer Error

2444H 55

Acetic Acid Container Failure

5 Transfer Error

2444I 55 Sodium


5 Transfer Error



5-81

5.20 DLA (Building 2462)


This building is DLA Headquarters. There are ASTs that are day tanks for backup power, a drum storage area, a fuel tank for small vehicles, and a chemical tank for boiler water treatment. An UST (2462B) is the main fuel storage tank (see Appendix A, Table A-2). Used food grease is also onsite (see Section 5.35). Table 5.20.1 provides container details, and Figure 5.20.1 shows their locations.

Table 5.20.1 DLA Containers

Container ID Type

Capacity (Gallons)


Product Stored

2462B UST 25,000 FRP Diesel 2462C AST, Horizontal 300 Steel Diesel 2462D AST, Horizontal 300 Steel Diesel 2462E AST, Horizontal 300 Steel Diesel 2462F AST, Horizontal 300 Steel Diesel 2462G AST, Horizontal 300 Steel Diesel 2462H AST, Horizontal 250 Steel Diesel

2462I AST, Vertical 65 Plastic Phosphoric Acid

2462DRA 55-Gallon Drums 55 (up to 4) Steel Used Oil



Contractor delivery trucks fill the diesel UST which pumps to the day tanks. The same trucks fill the fuel point tank. The fuel point tank (2462H) does not have a spill bucket to contain spills during disconnection (see Corrective Actions, Section 6.0). Chemicals are poured into the tank from small containers and then dispensed directly into the boiler water system. Used oil is manually poured into the drums. The drums are removed full for recycling, but are in improperly labeled drums (see Corrective Actions, Section 6.0). Table 5.20.2 provides product handling details.


5-82

Table 5.20.2 DLA Product Handling

Container ID Loading Method Overfill Protection Unloading Method 2462C Pump from UST Overfill Alarm Used in Generator 2462D Pump from UST Overfill Alarm Used in Generator 2462E Pump from UST Overfill Alarm Used in Generator 2462F Pump from UST Overfill Alarm Used in Generator 2462G Pump from UST Overfill Alarm Used in Generator

2462H Truck Sight Gauge Dispensed to Vehicles


2462DRA Manual Visual Removed Full



The day tank ASTs have steel dikes and do not collect storm water since they are inside generator buildings. The fuel dispensing and chemical tanks are double-walled. The drums are on spill containment pallets. Appendix D contains volume calculations for containers within diked areas.

Table 5.20.3 DLA Secondary Containment

Container ID Type Storm Water Release 2462C Steel Dike NA 2462D Steel Dike NA 2462E Steel Dike NA 2462F Steel Dike NA 2462G Steel Dike NA 2462H Double-Walled NA 2462I Double-Walled NA

2462DRA Spill Containment Pallets NA



5-83

Figure 5.20.1 DLA (Building 2462)


5-84




Complete container failure of an AST could result in a spill of up to 250 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow west in storm water pipes to the DLA ornamental pond and then south to Accotink Creek (see Figures 5.20.1, 2.1, and 2.5). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.20.4 DLA Potential Spill Scenarios

Container ID


2462B 3,000 Diesel Delivery Truck Error

West to ornamental pond and then

south to Accotink Creek

2462C 300 Diesel Container Failure

2462D 300 Diesel Container Failure

2462E 300 Diesel Container Failure


2462G 300 Diesel Container Failure

2462H

250

Diesel

Container Failure Southwest across ground to

ornamental pond and then south to Accotink Creek

25 Dispensing Error


2462I 65 Phosphoric

Acid Container Failure West to pond and

then south to Accotink Creek 5 Transfer Error

2462DRA 55

Used Oil Container Failure West to pond and

then south to Accotink Creek 5 Transfer Error



5-85

5.21 HECSA (Building 2580)


This area is operated by HECSA. There is an AST that dispenses kerosene for small heaters. Table 5.21.1 provides container details, and Figure 5.21.1 shows their locations.

Table 5.21.1 HECSA Containers

Container ID Type

Capacity (Gallons)


Product Stored

2580 AST, Horizontal 500 Steel Kerosene


Contractor delivery trucks fill the AST. A hand pump is used to dispense. Table 5.21.2 provides product handling details.

Table 5.21.2 HECSA Product Handling


2580 Truck Sight Gauge Dispensed to Heaters


The AST is double-walled and does not collect storm water.

Table 5.21.3 HECSA Secondary Containment



5-86

Figure 5.21.1 HECSA (Building 2580)


5-87




Complete container failure of an AST could result in a spill of up to 500 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow south in open drainage to Dogue Creek (see Figures 5.21.1, 2.1, and 2.3). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.21.4 HECSA Potential Spill Scenarios

Container ID


2580 500

Kerosene Container Failure South in open

drainage to Dogue Creek 3,000 Delivery Truck

Error


5-88

5.22 2800 Area (Buildings 2800 and 2803)


These buildings house administrative and utility services. There are ASTs that are day tanks for backup power (one of which is also a fuel tank for vehicles), a portable generator, and chemical drums for boiler water treatment. USTs are the main fuel storage tanks (see Appendix A, Table A-2). Used food grease is also onsite (see Section 5.35). Table 5.22.1 provides container details, and Figure 5.22.1 shows their locations.

Table 5.22.1 2800 Area Containers

Container ID Type

Capacity (Gallons)


Product Stored

2800C AST, Vertical 550 Steel Diesel

2800DRB 55-Gallon Drums 55 (up to 2) Plastic

Sodium Hydroxide, Cyclohexyl-

amine 2803B AST, Vertical 550 Steel Diesel 2803C AST, Horizontal 195 Steel Diesel

2803DR 55-Gallon Drums 55 (up to 2) Plastic Sodium

Hydroxide



Contractor delivery trucks fill the diesel USTs which pump to the day tanks. The same trucks fill the portable generator tank. Chemicals are poured into the drums from small containers and then dispensed directly into the boiler water system. Table 5.22.2 provides product handling details.


5-89

Table 5.22.2 2800 Area Product Handling

Container ID Loading Method Overfill Protection Unloading Method 2800C Pump from UST Overfill Alarm Used in Generator

2800DRB Manual Visual Used in Water Treatment

2803B Pump from UST Overfill Alarm Used in Generator

or Dispensed to Vehicles

2803C Truck Sight Gauge Used in Generator

2803DR Manual Visual Used in Water Treatment


The two day tanks (2800C and 2803B) and the portable generator (2803C) do not have secondary containment (see Corrective Actions, Section 6.0). The drums at 2800DRB are on spill containment pallets. The drums at 2803DR do not have secondary containment (see Corrective Actions, Section 6.0).

Table 5.22.3 2800 Area Secondary Containment

Container ID Type Storm Water Release 2800C None NA

2800DRB Spill Containment Pallets NA 2803B None NA 2803C None NA

2803DR None NA



5-90

Figure 5.22.1 2800 Area (Buildings 2800 and 2803)


5-91




Complete container failure of an AST could result in a spill of up to 550 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. It is assumed only one drum would spill in a given event. Any spill from this area would flow northeast across asphalt to a storm water inlet and then to an unnamed creek turning southeast to Dogue Creek (see Figures 5.22.1, 2.1, and 2.3). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.22.4 2800 Area Potential Spill Scenarios

Container ID


2800C 550 Diesel Container Failure Northeast and then southeast to Dogue

Creek

2800DRB 55 Sodium

Hydroxide, Cyclohexyl-

amine

Container Failure Northeast and then southeast to Dogue

Creek 5 Transfer Error

2803B 550


Northeast and then southeast to Dogue

Creek

25 Dispensing Error

2803C 195



2803DR 55 Sodium

Hydroxide Container Failure Northeast and then

southeast to Dogue Creek 5 Transfer Error



5-92

5.23 2800 Area (Building 2838)


Building 2838 is a fuel point for government owned vehicles. A UST holds gasoline for vehicles. Table 5.23.1 provides container details, and Figure 5.23.1 shows their locations.

Table 5.23.1 2800 Area Containers

Container ID Type

Capacity (Gallons)


Product Stored

2838A UST 5,000 Steel Gasoline


Contractor delivery trucks fill the UST. Fuel is dispensed into vehicles through a standard commercial pump. Table 5.23.2 provides product handling details.

Table 5.23.2 2800 Area Product Handling




The UST does not have to meet SPCC Plan requirements for secondary containment.




5-93

Figure 5.23.1 2800 Area (Building 2838)


5-94


An error dispensing fuel could spill 25 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow northeast in open drainage and then southeast to Dogue Creek (see Figures 5.23.1, 2.1, and 2.3). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.23.3 2800 Area Potential Spill Scenarios

Container ID


2838A 25

Gasoline Dispensing Error Northeast in open

drainage and then southeast to Dogue

Creek 3,000 Delivery Truck Error


5-95

5.24 Golf Course (Buildings 2909, 2990, and 2993)


The golf course includes a fuel point on the course and separate vehicle maintenance facilities. There are ASTs fueling vehicles, drums for maintenance, and pesticides for controlling weeds and insects. Used food grease is also onsite (see Section 5.35). Table 5.24.1 provides container details, and Figure 5.24.1 shows their locations.

Table 5.24.1 Golf Course Containers

Container ID Type

Capacity (Gallons)


Product Stored

2909A AST, Horizontal 500 Steel Gasoline 2909B AST, Horizontal 500 Steel Gasoline

2990A AST, Horizontal 275 Steel Used Antifreeze

2990B AST, Horizontal 275 Steel Used Oil 2990CU Buried Tank 2,000 Steel Heating Oil

2990DR 55-Gallon Drums 55 (up to 12) Steel

Oil, Hydraulic Oil,

Grease Antifreeze

2993C AST, Horizontal 500 Steel Gasoline 2993D AST, Horizontal 500 Steel Diesel

2993DRA 30-Gallon Drum 30 Plastic Prodiamine

2993DRB Various Various Plastic Various Herbicides



Contractor delivery trucks fill the fuel and heating oil tanks. Collection tanks are filled by pumping from smaller collection containers and emptied by vacuum truck. Drums have hand pumps for dispensing. The fuel point tanks on the course (2909A and 2909B) and the used oil tank and the buried heating oil tank in the maintenance area (2990B and 2990CU) do not have level gauges and spill buckets to prevent overfills (see Corrective Actions, Section 6.0). Table 5.24.2 provides product handling details.


5-96

Table 5.24.2 Golf Course Product Handling


2909A Truck None Dispensed to Vehicles

2909B Truck None Dispensed to Vehicles

2990A Pumped from Containers None Vacuum Truck

2990B Pumped from Containers Sight Gauge Vacuum Truck

2990CU Truck None Used in Heater

2990DR NA NA Dispensed for Maintenance

2993C Truck Sight Gauge Dispensed to Vehicles

2993D Truck Sight Gauge Dispensed to Vehicles

2993DRA NA NA Mixed for Application

2993DRB NA NA Mixed for Application


The two on course fuel tanks (2909B and 2909C), the used oil tank (2990B), and the drums in the maintenance area (2990DR) do not have secondary containment (see Corrective Actions, Section 6.0). The fuel tanks in the maintenance area are double-walled. The drums at 2993DRA are on spill containment pallets while the 2993DRB drums are in a containment conex.

Table 5.24.3 Golf Course Secondary Containment

Container ID Type Storm Water Release 2909A None NA 2909B None NA 2990A Double-walled NA 2990B None NA

2990CU None NA


5-97

2990DR None NA 2993C Double-walled NA 2993D Double-walled NA

2993DRA Spill Containment Pallets NA 2993DRB Steel Conex NA



5-98

Figure 5.24.1 Golf Course (Building 2909)


5-99

Figure 5.24.2 Golf Course (Buildings 2990 and 2993)


5-100




Complete container failure of an AST could result in a spill of up to 500 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. It is assumed only one drum would spill in a given event. Any spill from this area would flow south in open drainage and unnamed creek to Accotink Creek (see Figures 5.24.1, 2.1, and 2.3). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.24.4 Golf Course Potential Spill Scenarios

Container ID


2909A

500

Gasoline

Container Failure

South in open drainage to

Accotink Creek

25 Dispensing Error


2909B

500

Gasoline

Container Failure

25 Dispensing Error


2990A

275

Used Antifreeze



5 Transfer Error


2990B

275

Used Oil



5 Transfer Error



5-101

Container ID


2990CU 3,000 Heating Oil Delivery Truck Error


Accotink Creek

2990DR

55 Oil, Hydraulic

Oil, Grease


drainage to Accotink Creek 5 Dispensing Error

Antifreeze

2993C

500

Gasoline

Container Failure


Accotink Creek

25 Dispensing Error


2993D

500

Diesel

Container Failure

25 Dispensing Error


2993DRA 30

Prodiamine Container Failure


Accotink Creek

5 Mixing Error

2993DRA 30 Various

Herbicides Container Failure

5 Mixing Error



5-102

5.25 DAAF Hangar (Building 3121)


The hangar area includes aircraft maintenance facilities with drum storage areas. Table 5.25.1 provides container details, and Figure 5.25.1 shows their locations.

Table 5.25.1 Hangar Containers

Container ID Type

Capacity (Gallons)


Product Stored

3121DRA 55-Gallon Drums 55 (up to 12) Steel Used Oil,

Used Fuel


JP8


Used products are manually poured into the drums. Drums are emptied via vacuum truck. New product drums have hand pumps for dispensing. Table 5.25.2 provides product handling details.

Table 5.25.2 Hangar Product Handling

Container ID Loading Method Overfill Protection Unloading Method 3121DRA Manual Visual Vacuum Truck



The drums are in steel containment conexes.

Table 5.25.3 Hangar Secondary Containment

Container ID Type Storm Water Release 3121DRA Steel Conex NA 3121DRB Steel Conex NA


5-103

Figure 5.25.1 Hangar (Building 3121)


5-104


Records of monthly visual inspections and overfill protection system tests are maintained by area personnel for at least three years. Section 4.9 establishes the Fort Belvoir policies for the integrity testing of portable containers.


The loss of the entire contents of the vacuum tanker truck could spill 2,000 gallons. It is assumed only one drum would spill in a given event. Any spill from this area would flow northwest across concrete to a storm water inlet and then northeast before turning south to Accotink Creek (see Figures 5.25.1, 2.1, and 2.4). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.25.4 Hangar Potential Spill Scenarios

Container ID


3121DRA

55

Used Oil, Used Fuel

Container Failure

Northwest across concrete and then south to Accotink

Creek

5 Transfer Error


3121DRB 55 Oil,

JP8 Container Failure

5 Dispensing Error


5-105

5.26 DAAF Hangars (Buildings 3140 and 3144)



Table 5.26.1 Hangars Containers

Container ID Type

Capacity (Gallons)


Product Stored

3140DR 55-Gallon Drums 55 (up to 8) Steel Used Oil,

Used Fuel


Used Fuel


Used products are manually poured into the drums. Drums are emptied via vacuum truck. Table 5.26.2 provides product handling details.

Table 5.26.2 Hangars Product Handling

Container ID Loading Method Overfill Protection Unloading Method 3140DR Manual Visual Vacuum Truck 3144DR Manual Visual Vacuum Truck


The drums are on covered plastic containment pallets.

Table 5.26.3 Hangars Secondary Containment

Container ID Type Storm Water Release 3140DR Plastic Containment Pallet NA 3144DR Plastic Containment Pallet NA


5-106

Figure 5.26.1 Hangars (Buildings 3140 and 3144)


5-107





Table 5.26.4 Hangars Potential Spill Scenarios

Container ID


3140DR

55

Used Oil, Used Fuel

Container Failure


Creek

5 Transfer Error


3144DR

55

Used Oil, Used Fuel

Container Failure

5 Transfer Error



5-108



The hangar area includes aircraft maintenance facilities with drum storage areas and an office building with a heating oil tank. Table 5.27.1 provides container details, and Figure 5.27.1 shows their locations.


Container ID Type

Capacity (Gallons)


Product Stored


Used Fuel 3153A AST, Horizontal 550 Steel Heating Oil

3153DR 55-Gallon Drums 55 (up to 4) Steel Used Fuel


Contractor delivery trucks fill the heating oil tank. AST 3153A does not have a level gauge to prevent overfills (see Corrective Actions, Section 6.0). Used products are manually poured into the drums. Drums are emptied via vacuum truck. Table 5.27.2 provides product handling details.


Container ID Loading Method Overfill Protection Unloading Method 3151DR Manual Visual Vacuum Truck 3153A Truck Sight Gauge Used In Heater

3153DR Manual Visual Vacuum Truck


The AST is double-walled. The drums are on covered plastic containment pallets.


Container ID Type Storm Water Release 3151DR Plastic Containment Pallet NA 3153A Double-walled NA

3153DR Plastic Containment Pallet NA


5-109



5-110




Complete failure of the AST could spill 550 gallons. The loss of the entire contents of the fuel delivery truck could spill 3,000 gallons. The loss of the entire contents of the vacuum tanker truck could spill 2,000 gallons. It is assumed only one drum would spill in a given event. Any spill from this area would flow northwest across concrete to a storm water inlet and then northeast before turning south to Accotink Creek (see Figures 5.27.1, 2.1, and 2.4). A spill in this area would trigger the spill response procedures listed in Section 4.7.


Container ID


3151DR

55

Used Oil, Used Fuel

Container Failure Northwest across concrete and then south to Accotink

Creek

5 Transfer Error


3153A 550


South and then northeast and then south to Accotink

Creek


3153DR

55

Used Fuel

Container Failure

5 Transfer Error



5-111

5.28 DAAF Fuel Point (Building 3161)


The fuel point supplies fuel for all of the aircraft at DAAF. There are two USTs as the main fuel storage, five mobile refueler trucks that deliver fuel directly to aircraft on the flight line, two ASTs for fueling ground vehicles, and drums for collecting used fuel. Used food grease is also onsite (see Section 5.35). Table 5.28.1 provides container details, and Figure 5.28.1 shows their locations.

Table 5.28.1 DAAF Fuel Point Containers

Container ID Type

Capacity (Gallons)


Product Stored

3161A AST, Horizontal 500 Steel Gasoline 3161B AST, Horizontal 500 Steel Diesel


3161MA Mobile Refueler 5,000 Steel JP8 3161MB Mobile Refueler 3,000 Steel JP8 3161MC Mobile Refueler 3,000 Steel JP8 3161MD Mobile Refueler 3,000 Steel JP8 3161ME Mobile Refueler 3,000 Steel JP8 3162AU UST 13,000 FRP JP8 3162BU UST 13,000 FRP JP8


Contractor delivery trucks fill the USTs and the fuel tanks. The USTs fill the mobile refuelers at the loading/unloading rack. Collection drums are filled manually from small containers and emptied by vacuum truck. Mobile refueler trucks dispense fuel directly to aircraft. Table 5.28.2 provides product handling details.


5-112

Table 5.28.2 DAAF Fuel Point Product Handling


3161A Truck Sight Gauge Dispensed to Vehicles

3161B Truck Sight Gauge Dispensed to Vehicles

3161DR Manual Visual Vacuum Truck

3161MA Pumped from USTs Sight Gauge Dispensed to

Aircraft

3161MB Pumped from USTs Sight Gauge Dispensed to

Aircraft

3161MC Pumped from USTs Sight Gauge Dispensed to

Aircraft

3161MD Pumped from USTs Sight Gauge Dispensed to

Aircraft

3161ME Pumped from USTs Sight Gauge Dispensed to

Aircraft


The two ground vehicle fuel tanks (3161A and 3161B) are double-walled. The drums are in a covered plastic containment pallet. The mobile refueler trucks are parked in a concrete containment area. The loading/unloading rack is contained by a concrete berm. Appendix D contains volume calculations for containers within diked areas and the loading/unloading rack. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.28.3 DAAF Fuel Point Secondary Containment

Container ID Type Storm Water Release 3161A Double-walled NA 3161B Double-walled NA

3161DR Plastic Containment Pallet NA 3161MA Concrete Dike Manual 3161MB Concrete Dike Manual 3161MC Concrete Dike Manual 3161MD Concrete Dike Manual 3161ME Concrete Dike Manual


5-113

Figure 5.28.1 DAAF Fuel Point (Building 3161)


5-114




Complete container failure of an AST could result in a spill of up to 500 gallons. The loss of the entire contents of the larger fuel delivery tanker truck could spill 5,000 gallons. The loss of the entire contents of the vacuum truck could spill 2,000 gallons. It is assumed only one drum would spill in a given event. Any spill from this area would flow northwest across concrete to a storm water inlet and then northeast before turning south to Accotink Creek (see Figures 5.28.1, 2.1, and 2.4). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.28.4 DAAF Fuel Point Potential Spill Scenarios

Container ID


3161A

500

Gasoline

Container Failure


Creek

25 Dispensing Error


3161B

500

Diesel

Container Failure

25 Dispensing Error


3161DR

55

Used Fuel

Container Failure

5 Transfer Error


3161MA 5,000


50 Filling Error

3161MB 3,000


50 Filling Error


5-115

Container ID


3161MC 3,000



Creek

50 Filling Error

3161MD 3,000


50 Filling Error

3161ME 3,000


50 Filling Error

3162AU 5,000 JP8 Delivery Truck Error

3162BU 5,000 JP8 Delivery Truck Error


5-116





Container ID Type

Capacity (Gallons)


Product Stored




Used products are manually poured into the drums. Drums are emptied via vacuum truck. Table 5.29.2 provides product handling details.


Container ID Loading Method Overfill Protection Unloading Method 3231DR Manual Visual Vacuum Truck 3232DR Manual Visual Vacuum Truck


The drums are on covered plastic containment pallets.


Container ID Type Storm Water Release 3231DR Plastic Containment Pallets NA 3232DR Plastic Containment Pallets NA


5-117



5-118






Container ID


3231DR

55

Used Oil

Container Failure


Creek

5 Transfer Error


3232DR

55

Used Fuel

Container Failure

5 Transfer Error



5-119

5.30 NGA (Buildings 5103 and 5104)


The NGA facility includes fuel storage tanks and day tanks for emergency generators, plus water treatment chemicals, and used oil collection drums. Table 5.30.1 provides container details, and Figure 5.26.1 shows their locations.

Table 5.30.1 NGA Containers

Container ID Type

Capacity (Gallons)


Product Stored

5103A AST, Horizontal 400 Steel Diesel 5103B AST, Horizontal 400 Steel Diesel 5103C AST, Horizontal 400 Steel Diesel 5103D AST, Horizontal 400 Steel Diesel 5103E AST, Horizontal 400 Steel Diesel 5103F AST, Horizontal 400 Steel Diesel 5103G AST, Horizontal 400 Steel Diesel 5103H AST, Horizontal 500 Steel Diesel 5103I AST, Horizontal 500 Steel Diesel 5103J AST, Horizontal 500 Steel Diesel 5104A AST, Horizontal 10,000 Steel Diesel 5104B AST, Horizontal 30,000 Steel Diesel 5104C AST, Horizontal 30,000 Steel Diesel 5104D AST, Horizontal 30,000 Steel Diesel 5104E AST, Horizontal 30,000 Steel Diesel 5104F AST, Horizontal 30,000 Steel Diesel 5104G AST, Horizontal 30,000 Steel Diesel 5104H AST, Horizontal 400 Steel Diesel 5104I AST, Horizontal 110 Plastic Glutaraldehyde

5104J AST, Horizontal 110 Plastic Phosphonic Acid

5104K AST, Horizontal 110 Plastic Sodium Hypochlorite

5104L AST, Vertical 200 Plastic Sodium Hydroxide

5104DR 55-Gallon Drums 55 (up to 4) Plastic Used Oil


5-120


Contractor delivery trucks fill the receiving diesel tank (5104A). Diesel is distributed from AST 5104A into the 30,000-gallon tanks for storage. The diesel is then transferred via underground piping to the emergency generator day tanks (5103A-5103J). Oil collection drums are filled by manually pouring from smaller collection containers and then the entire drum is removed for recycling. Water treatment chemical tanks have automatic pumps for dispensing directly into the boiler water system. Table 5.30.2 provides product handling details.

Table 5.30.2 NGA Product Handling


5103A - 5103J Pumped from ASTs Overfill Alarms Used in Generators

5104A Truck

Automatic Tank Gauging,

Overfill Alarms, Automatic Shut-Off

Pumped to ASTs

5104B – 5104G Pumped from 5104A

Overfill Alarms, Automatic Shut-Off

Pumped to Day Tanks

5104H Pumped from ASTs Overfill Alarms Used in Generator

5104I – 5104L Manual Visual Used in Water Treatment

5104DR Manual Visual NA


The diesel tanks are all double-walled. The water treatment chemical tanks have dikes for secondary containment. The drums at 5104DR are on spill containment pallets which are not large enough to hold their entire volume (see Corrective Actions, Section 6.0). See Appendix D for volume calculations of diked areas.


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Table 5.30.3 NGA Secondary Containment

Container ID Type Storm Water Release 5103A - 5103J Double-walled NA

5104A Double-walled NA 5104B – 5104G Double-walled NA

5104H Double-walled NA 5104I Plastic Dike NA 5104J Stainless Steel Dike NA 5104K Plastic Dike NA 5104L Plastic Dike NA

5104DR Spill Containment Pallets NA



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Figure 5.30.1 NGA (Buildings 5103 and 5104)


5-123


Records of certified inspections (for tanks greater than 5,000 gallons) are maintained by DPW Environmental for the life of the container. Records of monthly visual inspections and overfill protection system tests are maintained by area personnel for at least three years. Sections 4.8 and 4.9 establish the Fort Belvoir policies for the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity and portable containers.


Complete container failure of an AST could result in a spill of up to 30,000 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 5,000 gallons. It is assumed only one drum would spill in a given event. Any spill from this area would flow north to a storm water inlet and then southeast to a storm water pond and then south to Accotink Creek (see Figures 5.30.1, 2.1, and 2.2). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.30.4 NGA Potential Spill Scenarios

Container ID


5103A – 5103G

400 Diesel

Container Failure North to storm

water inlet and then southeast to a

storm water pond and south to

Accotink Creek

25 Pump Transfer Error

5103H – 5103J

500 Diesel

Container Failure


5104A

10,000

Diesel

Container Failure

North to storm water inlet and then

southeast to a storm water pond

and south to Accotink Creek



5104B – 5104G 30,000 Diesel Container Failure

5104H 400


25 Dispensing Error


5-124

5104I 110

Glutaraldehyde Container Failure

North to storm water inlet and then



5 Transfer Error

5104J 110 Phosphonic

Acid Container Failure

5 Transfer Error

5104K 110 Sodium


5 Transfer Error

5104L 200 Sodium


5 Transfer Error

5104DR

55

Used Oil

Container Failure North to storm water inlet and then



5 Transfer Error



5-125

5.31 Tulley Gate (Building 9500)


The Tulley Gate has a visitor center with an emergency generator and a fuel tank for filling space heaters used by guards. Table 5.31.1 provides container details, and Figure 5.31.1 shows their locations.

Table 5.31.1 Tulley Gate Containers

Container ID Type

Capacity (Gallons)


Product Stored

9500A AST, Horizontal 500 Steel Diesel 9500B AST, Horizontal 500 Steel Kerosene


Contractor delivery trucks fill the fuel and generator tanks. The kerosene tank does not have a level gauge to prevent overfills (see Corrective Actions, Section 6.0). The kerosene tank has a hand dispenser pump for filling space heaters. Table 5.31.2 provides product handling details.

Table 5.31.2 Tulley Gate Product Handling

Container ID Loading Method Overfill Protection Unloading Method 9500A Truck Sight Gauge Used in Generator

9500B Truck None Dispensed to Heaters


The tanks are double-walled and do not collect storm water.

Table 5.31.3 Tulley Gate Secondary Containment

Container ID Type Storm Water Release 9500A Double-walled NA 9500B Double-walled NA


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Figure 5.31.1 Tulley Gate (Building 9500)


5-127




Complete container failure of an AST could result in a spill of up to 500 gallons. The loss of the entire contents of the fuel delivery tanker truck could spill 3,000 gallons. Any spill from this area would flow west in open drainage to Accotink Creek (see Figures 5.31.1, 2.1, and 2.6). A spill in this area would trigger the spill response procedures listed in Section 4.7.

Table 5.31.4 Tulley Gate Potential Spill Scenarios

Container ID


9500A 308


West in open drainage to

Accotink Creek


9500B

500

Kerosene

Container Failure

10 Dispensing Error



5-128

5.32 Electrical Transformers


Oil-filled electrical transformers are located throughout Fort Belvoir, typically near large buildings. There are no PCB-containing transformers on Fort Belvoir. The electrical system at Fort Belvoir has been privatized and is now owned and operated by the Old Dominion Power Company. Old Dominion is responsible for determining applicability and maintaining a SPCC Plan as necessary. Old Dominion personnel also maintain many pole mounted transformers with oil storage capacities less than 55 gallons. The pad mounted transformers and the primary transformers at the electrical substation all contain more than 55 gallons of oil.

There are some areas of Fort Belvoir where the electrical system is still owned and operated by the Army. Two of the Army owned transformers contain a vegetable-based oil, while the others all contain traditional mineral oil. Electrical operating equipment is specifically excluded from the definition of bulk storage containers in 40 CFR 112.2. This means that requirements for secondary containment, integrity testing, and spill and overfill prevention do not apply. However, there is still a requirement for appropriate containment and diversionary structures to prevent a spill from reaching navigable waters (40 CFR 112.7(c)). Amendments to 40 CFR 112 (5 December 2008) exempt “oil-filled operational equipment” (such as transformers) from secondary containment requirements if inspection procedures are documented and a spill contingency plan, with a commitment to control any spills, is prepared.

Table 5.32.1 shows the transformer capacities, and the Fort Belvoir Containers and Drainage Map and Area Overview Map, Figures 2.2, 2.3, and 2.4 show the transformer locations and potential spill routes. There has never been a discharge from a transformer at Fort Belvoir.


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Table 5.32.1 Electrical Transformers

Transformer ID Capacity (Gallons) T5103A 5,380 T5103B 5,380 T2500A 785 T2500B 1,240 T2584 225 T2592 350 T2593 388 T2594 365 T2596 500


Transformer maintenance includes monitoring the oil level and testing for dissolved gases in the oil. If the oil level drops below the required level, maintenance personnel add new oil. If the oil quality degrades below standards, then maintenance personnel replace the oil or hire a contractor to perform this service. These events are rare, and in both cases personnel manually fill the containers from 5 gallon or smaller containers and use drip pans and rags to catch any small spills. Typically, DPW personnel simply replace an entire transformer if a problem develops. New transformers arrive full of oil, and old transformers are shipped away with their contents intact.


The SPCC regulations require documented inspection procedures and a spill contingency plan, with a commitment to control any spills from oil-filled electrical equipment to prevent a discharge and contain oil until cleanup occurs. A large spill from a transformer would result in power loss and immediate attention from installation personnel. Response personnel would deploy sorbent materials to contain any spilled oil at that time. Personnel may also use portions of Fort Belvoir’s storm water system to contain a spill prior to contact with navigable waters.


DPW personnel inspect and test transformers when sensors indicate reduced performance. This is similar to having an automatic monitoring system and provides


5-130

more environmental protection than monthly inspections. If a transformer develops a leak, it will be checked immediately. At that time, oil level and oil quality may be checked. The Institute for Electronic and Electrical Engineers Standard 62, Guide for Diagnostic Field Testing of Electric Power Apparatus, recommends common, practical diagnostic procedures to assist electrical maintenance personnel in establishing a maintenance schedule for oil-filled electrical equipment. This standard relies heavily upon manufacturer’s recommendations for inspections and testing. DPW personnel follow these recommendations and perform visual inspections every three years or when necessary. Records of these inspections are maintained for three years.

5.32.5 Potential Spill Scenario

Catastrophic failure of one of the larger transformers may release more than five thousand gallons of vegetable oil. Facility personnel would respond appropriately according to the procedures outlined in Section 4.7 and prevent the spill from reaching navigable waters (see Figures 2.1, 2.2, and 2.3).


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5.33 Emergency Generators


Diesel emergency generators are used throughout Fort Belvoir to ensure constant power supplies. Some of the generators are piped to ASTs that provide diesel fuel while others have an internal diesel tank. Table 5.33.1 provides container details, and Figure 2.1 shows their locations.

Table 5.33.1 Emergency Generators

Container ID Type

Capacity (Gallons)


Product Stored

97 AST, Horizontal 750 Steel Diesel 193B AST, Horizontal 500 Steel Diesel 200 AST, Horizontal 315 Steel Diesel 238 AST, Horizontal 676 Steel Diesel

246D AST, Horizontal 1,000 Steel Diesel 314A AST, Horizontal 150 Steel Diesel 315 AST, Horizontal 150 Steel Diesel

319A AST, Horizontal 475 Steel Diesel 319B AST, Horizontal 475 Steel Diesel 363C AST, Horizontal 250 Steel Diesel 367A AST, Horizontal 1,500 Steel Diesel 367B AST, Horizontal 240 Steel Diesel 380B AST, Horizontal 475 Steel Diesel 399 AST, Horizontal 520 Steel Diesel

584A AST, Horizontal 156 Steel Diesel 594B AST, Horizontal 250 Steel Diesel 687B AST, Horizontal 500 Steel Diesel 765A AST, Horizontal 3,000 Steel Diesel 765B AST, Horizontal 5,000 Steel Diesel 765C AST, Horizontal 700 Steel Diesel 767 AST, Horizontal 275 Steel Diesel

952A AST, Horizontal 250 Steel Diesel 1156A AST, Horizontal 112 Steel Diesel


5-132

Table 5.33.1 Emergency Generators (Continued)

Container ID Type

Capacity (Gallons)


Product Stored

1204 AST, Horizontal 505 Steel Diesel 1260 AST, Horizontal 1,705 Steel Diesel 1262 AST, Horizontal 1,705 Steel Diesel

1421B AST, Horizontal 250 Steel Diesel 1456A AST, Horizontal 461 Steel Diesel 1465A AST, Horizontal 250 Steel Diesel 1465B AST, Horizontal 112 Steel Diesel 1576 AST, Horizontal 150 Steel Diesel 1589 AST, Horizontal 112 Steel Diesel

1822D AST, Horizontal 250 Steel Diesel 1822E AST, Horizontal 250 Steel Diesel 1832 AST, Horizontal 250 Steel Diesel

2445C AST, Horizontal 250 Steel Diesel 2454A AST, Horizontal 250 Steel Diesel 2470 AST, Horizontal 250 Steel Diesel 2494 AST, Horizontal 112 Steel Diesel

2590A AST, Horizontal 500 Steel Diesel 2591B AST, Horizontal 500 Steel Diesel 2592E AST, Horizontal 3,225 Steel Diesel 2592F AST, Horizontal 800 Steel Diesel 2593C AST, Horizontal 2,000 Steel Diesel 2594E AST, Horizontal 165 Steel Diesel 2594F AST, Horizontal 800 Steel Diesel 2596A AST, Horizontal 1,369 Steel Diesel 2596B AST, Horizontal 1,369 Steel Diesel 2597 AST, Horizontal 105 Steel Diesel 2809 AST, Horizontal 415 Steel Diesel

2810D AST, Horizontal 2,500 Steel Diesel 2822 AST, Horizontal 195 Steel Diesel

2849A AST, Horizontal 110 Steel Diesel


5-133

Container ID Type

Capacity (Gallons)


Product Stored

2849B AST, Horizontal 500 Steel Diesel 2849C AST, Horizontal 125 Steel Diesel 2857A AST, Horizontal 140 Steel Diesel 2857B AST, Horizontal 140 Steel Diesel 2857C AST, Horizontal 140 Steel Diesel 2857D AST, Horizontal 140 Steel Diesel 2857E AST, Horizontal 140 Steel Diesel 2857F AST, Horizontal 140 Steel Diesel 2857G AST, Horizontal 140 Steel Diesel 2857H AST, Horizontal 140 Steel Diesel 2857I AST, Horizontal 140 Steel Diesel 2857J AST, Horizontal 140 Steel Diesel 2857K AST, Horizontal 140 Steel Diesel 2857L AST, Horizontal 140 Steel Diesel 2857M AST, Horizontal 140 Steel Diesel 2857N AST, Horizontal 140 Steel Diesel 2857O AST, Horizontal 100 Steel Diesel 2857P AST, Horizontal 100 Steel Diesel 2935 AST, Horizontal 112 Steel Diesel 3138J AST, Horizontal 1,000 Steel Diesel 3165A AST, Horizontal 500 Steel Diesel 3209 AST, Horizontal 250 Steel Diesel 3229 AST, Horizontal 250 Steel Diesel 3238 AST, Horizontal 105 Steel Diesel

3239A AST, Horizontal 250 Steel Diesel 3242 AST, Horizontal 500 Steel Diesel DAAF Gate AST, Horizontal 112 Steel Diesel

5101 AST, Horizontal 350 Steel Diesel 7336A AST, Horizontal 250 Steel Diesel 7352A AST, Horizontal 156 Steel Diesel


5-134


Personnel use a 3,000 gallon tanker truck to fill most generator fuel tanks. Personnel follow the truck unloading procedures described in Section 4.13. The truck is equipped with a spill kit for cleaning up small spills and drips. Tanks 1822E, 2849A, and 3138J do not have level gauges to prevent overfills (See Section 6.0, Corrective Actions). Tanks 765C, 2594E, and 2857A through 2857N are day tanks for emergency generators and are not directly filled from the delivery truck. These tanks are filled by pump from associated larger storage tanks. ASTs 2857O and 2857 P are overflow tanks for the 2857 system and are not normally filled.

Table 5.33.2 Emergency Generator Product Handling

Container ID Loading Method Overfill Protection Unloading Method All Generator Tanks (unless listed below)

Truck Sight Gauge Used in Generator

765C Pumped from 765B Overfill Alarm Used in Generator

2594E Pumped from UST 2594A Overfill Alarm Used in Generator

2857A – 2857N Pumped from UST 2856B Overfill Alarm Used in Generator

2857O and 2857P

Overflow from 2857A – 2857N Overfill Alarm Returned by pump

to 2857A – 2857N


Most generators have double-walled ASTs. Generators 2809 and 2822 do not have secondary containment (See Section 6.0, Corrective Actions). Single-walled tanks 246D and 767 are inside buildings and do not collect storm water. The containment area for 767 is not large enough to hold the tank volume (See Section 6.0, Corrective Actions). The tank and metal secondary containment for AST 1822E are so corroded that holes may develop (See Section 6.0, Corrective Actions). Tank 193B is partially buried under accumulated soil which could cause corrosion (See Section 6.0, Corrective Actions). Appendix D contains volume calculations for generators within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.


5-135

Table 5.33.3 Emergency Generators Secondary Containment


193B Double-walled NA 200 Double-walled NA 238 Double-walled NA

246D Steel Dike NA (indoors) 314A Double-walled NA 315 Double-walled NA

319A Double-walled NA 319B Double-walled NA 363C Double-walled NA 367A Double-walled NA 367B Double-walled NA 380B Double-walled NA 399 Double-walled NA

584A Double-walled NA 594B Double-walled NA 687B Double-walled NA 765A Double-walled NA 765B Double-walled NA 765C Double-walled NA 767 Concrete Dike NA (indoors)

952A Double-walled NA 1156A Double-walled NA 1204 Double-walled NA 1260 Double-walled NA 1262 Double-walled NA

1421B Double-walled NA 1456A Double-walled NA 1465A Double-walled NA 1465B Double-walled NA 1576 Double-walled NA


5-136


1822D Double-walled NA 1822E Steel Dike Manual

1832 Double-walled NA

2445C Double-walled NA 2454A Double-walled NA 2470 Double-walled NA 2494 Double-walled NA

2590A Double-walled NA 2591B Double-walled NA 2592E Double-walled NA 2592F Double-walled NA 2593C Double-walled NA 2594E Double-walled NA 2594F Double-walled NA 2596A Double-walled NA 2596B Double-walled NA 2597 Double-walled NA 2809 None NA

2810D Double-walled NA 2822 None NA

2849A Double-walled NA 2849B Double-walled NA 2849C Double-walled NA 2857A Double-walled NA 2857B Double-walled NA 2857C Double-walled NA 2857D Double-walled NA 2857E Double-walled NA 2857F Double-walled NA 2857G Double-walled NA 2857H Double-walled NA


5-137

Container ID Type Storm Water Release 2857I Double-walled NA 2857J Double-walled NA 2857K Double-walled NA 2857L Double-walled NA 2857M Double-walled NA 2857N Double-walled NA 2857O Double-walled NA 2857P Double-walled NA 2935 Double-walled NA 3138J Double-walled NA 3165A Double-walled NA 3209 Double-walled NA 3229 Double-walled NA 3238 Double-walled NA

3239A Double-walled NA 3242 Double-walled NA

DAAF Gate Double-walled NA 5101 Double-walled NA

7336A Double-walled NA 7352A Double-walled NA


Records of monthly visual inspections and overfill protection system tests are maintained for at least three years by DPW Environmental. Section 4.8 establishes the Fort Belvoir policy for the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity.


Complete failure of one emergency generator tank could result in a 5,000 gallon spill. The loss of the entire contents of the delivery tanker truck could spill 3,000 gallons at any generator location. Fuel delivery trucks park next to the generators when they are filling them; a spill due to either container failure or delivery truck error at any emergency generator location could flow to Accotink Creek/Bay, Dogue Creek/Bay, or the Potomac River depending on the location of the generator (see Figures 2.1 through


5-138

2.7). A spill in any of these areas would trigger the spill response procedures listed in Section 4.7.

Table 5.33.4 Emergency Generators Potential Spill Scenarios

Container ID


97 750


East to Dogue Bay 3,000 Delivery Truck Error

193B 500


West to Accotink Bay 3,000 Delivery Truck Error

200 315



238 676



246D 1,000



314A 150


South to Potomac River 3,000 Delivery Truck Error

315 150



319A 475



319B 475



363C 250



367A 1,500



367B 240



380B 475




5-139

Table 5.33.4 Emergency Generators Potential Spill Scenarios (Continued)

Container ID


399 520



584A 156



594B 250



687B 500



765A 3,000


West to Accotink Bay


765B 5,000



765C 700



767 275



952A 250



1156A 112



1204 525


East to Dogue Creek 3,000 Delivery Truck Error

1260 1,705



1262 1,705



1421B 250


West to Accotink Creek 3,000 Delivery Truck Error

1456A 461




5-140

1465A 250



1465B 112



1576 150


East to Dogue Creek 3,000 Delivery Truck Error

1589 112


West to Dogue Creek 3,000 Delivery Truck Error

1822D 250



1822E 250



1832B 250



2445C 250


South to Accotink Creek 3,000 Delivery Truck Error

2454A 250



2470 250



2590A 500


South to Dogue Creek 3,000 Delivery Truck Error

2591B 500



2592E 3,225



2592F 800



2593C 2,000



2594E 165



2594F 800




5-141

2596A 1,369



2596B 1,369



2597 2,000



2809 415

Diesel Container Failure Northeast and then

south to Dogue Creek 3,000 Delivery Truck Error

2810D 2,500



2822 195



28 Gate 125



2849A 110


Northeast and then south to Dogue Creek


2849B 500



2857A – 2857N

140 Diesel

Container Failure Northeast and then

south to Dogue Creek 50 Pump Transfer Error

2857O – 2857P 100 Diesel Container Failure

2935 112



3138J 1,000


south to Accotink Creek 3,000 Delivery Truck Error

3165A 500



3209 250



3229 250



3238 105




5-142

3239A 250



3242 500



DAAF Gate

112 Diesel

Container Failure South to Accotink Creek


5101 350



7336A 250



7352A 156




5-143

5.34 Heating Oil Tanks


Heating oil tanks are used throughout Fort Belvoir at locations that do not have natural gas lines available for heating. This section includes completely buried heating oil tanks that are excluded from the definition of USTs in 40 CFR 280 but are regulated by 40 CFR 112 (not including single family residences). Completely buried heating oil tanks have the suffix “U” on the container ID. Table 5.34.1 provides container details, and Figure 2.1 shows their locations.

Table 5.34.1 Heating Oil Tanks

Container ID Type

Capacity (Gallons)


Product Stored

193CU Buried Tank 1,000 FRP Heating Oil 332HU Buried Tank 25,000 FRP Heating Oil 332IU Buried Tank 25,000 FRP Heating Oil 332JU Buried Tank 25,000 FRP Heating Oil 374A AST, Horizontal 275 Steel Heating Oil 374B AST, Horizontal 275 Steel Heating Oil

380AU Buried Tank 1,000 Steel Heating Oil 780B AST, Horizontal 500 Steel Heating Oil

1141A AST, Horizontal 550 Steel Heating Oil 1142A AST, Horizontal 550 Steel Heating Oil 1143A AST, Horizontal 550 Steel Heating Oil 1143B AST, Horizontal 550 Steel Heating Oil 1157A AST, Horizontal 550 Steel Heating Oil 1412A AST, Horizontal 550 Steel Heating Oil 1412B AST, Horizontal 550 Steel Heating Oil

1422PU Buried Tank 25,000 FRP Heating Oil 1422QU Buried Tank 25,000 FRP Heating Oil 1422RU Buried Tank 25,000 FRP Heating Oil 1422SU Buried Tank 25,000 FRP Heating Oil 1422TU Buried Tank 25,000 FRP Heating Oil 1436D AST, Horizontal 2,000 Steel Heating Oil


5-144

Table 5.34.1 Heating Oil Tanks (Continued)

Container ID Type

Capacity (Gallons)


Product Stored

1444 AST, Horizontal 1,000 Steel Heating Oil 1700AU Buried Tank 5,000 FRP Heating Oil 1810AU Buried Tank 8,000 Steel Heating Oil 1970D AST, Horizontal 500 Steel Heating Oil 1976C AST, Horizontal 1,000 Steel Heating Oil 1980A AST, Horizontal 500 Steel Heating Oil 1981U Buried Tank 550 Steel Heating Oil 2117U Buried Tank 25,000 FRP Heating Oil

2473BU Buried Tank 5,000 FRP Heating Oil 2476A AST, Horizontal 500 Steel Heating Oil

2582BU Buried Tank 2,500 FRP Heating Oil 2584BU Buried Tank 5,000 FRP Heating Oil 2592DU Buried Tank 5,000 FRP Heating Oil

2827 AST, Horizontal 640 Steel Heating Oil 3138HU Buried Tank 30,000 FRP Heating Oil 3138IU Buried Tank 30,000 FRP Heating Oil


Personnel use a 3,000 gallon tanker truck to fill heating oil tanks following the truck unloading procedures described in Section 4.13. The truck is equipped with a spill kit for cleaning up small spills and drips. Tanks 374A, 374B, 780B, and 1976C do not have level gauges to prevent overfills (See Section 6.0, Corrective Actions). Heating oil is used to fuel boilers and heaters within adjacent buildings.

Table 5.34.2 Heating Oil Tanks Product Handling

Container ID Loading Method Overfill Protection Unloading Method All Heating Oil

Tanks Truck Sight Gauge Used in Boiler/Heater


5-145


Most aboveground heating oil tanks are double-walled. ASTs 374A, 374B, 780B, 1412A, 1412B, and 1976C do not have secondary containment (See Section 6.0, Corrective Actions). Buried heating oil tanks 380AU, 1810AU, and 1981U do not have secondary containment and do not have equivalent environmental protection (See Section 6.0, Corrective Actions). Appendix D contains volume calculations for heating oil tanks within diked areas. Personnel follow the rainwater release procedures found in Section 4.10.

Table 5.34.3 Heating Oil Tanks Secondary Containment

Container ID Type Storm Water Release 193CU Double-walled NA 332HU Double-walled NA 332IU Double-walled NA 332JU Double-walled NA 374A None NA 374B None NA

380AU None NA 780B None NA

1141A Double-walled NA 1142A Double-walled NA 1143A Double-walled NA 1143B Double-walled NA 1157A Double-walled NA 1412A None NA 1412B None NA

1422PU Double-walled NA 1422QU Double-walled NA 1422RU Double-walled NA 1422SU Double-walled NA 1422TU Double-walled NA 1436D Double-walled NA 1444 Double-walled NA

1700AU Double-walled NA


5-146

Container ID Type Storm Water Release 1810AU None NA 1970D Double-walled NA 1976C None NA 1980A Double-walled NA 1981U None NA 2117U Double-walled NA

2473BU Double-walled NA 2476A None NA

2582BU Double-walled NA 2584BU Double-walled Manual

2592DU Double-walled NA

2827 Double-walled NA 3138HU Double-walled NA 3138IU Double-walled NA


Records of certified inspections (for tanks greater than 5,000 gallons) are maintained by DPW Environmental for the life of the container. Records of monthly visual inspections and overfill protection system tests are maintained for at least three years by DPW Environmental. Section 4.8 establishes the Fort Belvoir policy for the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity.


Complete failure of one heating oil tank could result in a 5,000 gallon spill. The loss of the entire contents of the delivery tanker truck could spill 3,000 gallons at any location. Fuel delivery trucks park next to the heating oil tanks when they are filling them; a spill due to either container failure or delivery truck error at any heating oil tank location could flow to Accotink Creek/Bay, Dogue Creek/Bay, or the Potomac River depending on the location of the heating oil tank (see Figures 2.1 through 2.7). A spill in any of these areas would trigger the spill response procedures listed in Section 4.7.


5-147

Table 5.34.4 Heating Oil Tanks Potential Spill Scenarios

Container ID


193CU 1,000 Heating



332HU 25,000 Heating


South to Potomac River


332IU 25,000 Heating



332JU 25,000 Heating



374A 275 Heating



374B 275 Heating



380AU 1,000 Heating



780B 500 Heating



1141A 550 Heating


West to Accotink Bay


1142A 550 Heating



1143A 550 Heating



1143B 550 Heating



1157A 550 Heating




5-148

Table 5.34.4 Heating Oil Tanks Potential Spill Scenarios (Continued)

Container ID


1412A 550 Heating



1412B 550 Heating



1422PU 25,000 Heating




1422QU 25,000 Heating



1422RU 25,000 Heating



1422SU 25,000 Heating



1422TU 25,000 Heating



1436D 2,000 Heating



1444 1,000 Heating



1700AU 5,000 Heating

Oil Container Failure North and then south to

Dogue Creek 3,000 Delivery Truck Error

1810AU 8,000 Heating

Oil Container Failure North and then west to

Accotink Creek 3,000 Delivery Truck Error

1970D 500 Heating



1976C 1,000 Heating



1980A 500 Heating



1981U 550 Heating




5-149

Table 5.34.4 Heating Oil Tanks Potential Spill Scenarios (Continued)

Container ID


2117U 25,000 Heating

Oil Container Failure North and then west to


2473BU 5,000 Heating



2476A 500 Heating





South to Dogue Creek





2592DU 5,000 Heating



2827 640 Heating



3138HU 30,000 Heating


Northeast and then south to Accotink Creek


3138IU 30,000 Heating




5-150

5.35 Used Food Grease Containers


There are 10 locations that store used food grease in outdoor containers on Fort Belvoir. The sites use one of three methods for storage and handling. Some use standard steel 55-gallon drums with manual pouring. Others use steel grease containers similar to small dumpsters (grease bins) with flip open lids and manual pouring. Lastly, some locations use vertically-oriented stainless steel cylindrical tanks with electric pumping. Table 5.35.1 provides details for the grease containers, and the Fort Belvoir Containers and Drainage Map, Figure 2.1, shows locations and flow directions.

Table 5.35.1 Used Food Grease Containers

Container ID Type

Capacity (Gallons)

Material of Construction Product Stored

20 AST, Horizontal 200 Steel Used Food Grease


1135D AST, Vertical 240 Stainless Steel Used Food Grease


1200DR 55-Gallon Drums

55 (up to 4) Steel Used Food Grease

1456B AST, Horizontal 85 Steel Used Food Grease

2303 AST, Vertical 350 Stainless Steel Used Food Grease

2304E AST, Horizontal 200 Steel Used Food Grease

2444J AST, Horizontal 200 Steel Used Food Grease

2462DRB 55-Gallon Drums


2800DRA 55-Gallon Drums




5-151


The oil and grease is brought out to the drums and grease bins in small buckets or jugs for manual pouring. The stainless steel tanks are directly hard piped to the frying vats and grease is pumped to the tanks by electric pump. The tanks and drums are then emptied by a contractor vacuum truck. Table 5.35.2 provides more details regarding product handling activities for this area.

Table 5.35.2 Used Food Grease Product Handling

Container ID Loading Method Overfill Protection Unloading Method 20 Manual Visual Truck

321 Manual Visual Truck 1135D Electric Pump High Level Alarm Truck 1199 Manual Visual Truck

1200DR Manual Visual Truck 1456B Manual Visual Truck 2303 Electric Pump High Level Alarm Truck

2304E Manual Visual Truck 2444J Manual Visual Truck

2462DRB Manual Visual Truck 2800DRA Manual Visual Truck

2920 Manual Visual Truck


Drums 2800DRA are on a containment pallet, but the pallet is too small. The containers are all single-walled and do not have required secondary containment (See Section 6.0, Corrective Actions). 2462DR and 1135D are inside buildings that may provide some secondary containment prior to release out doors or floor drains.


5-152

Table 5.35.3 Used Food Grease Secondary Containment

Container ID Type Storm Water Release 20 None NA

321 None NA 1135D None NA 1199 None NA

1200DR None NA 1456B None NA 2303 None NA

2304E None NA 2444J None NA

2462DRB None NA 2800DRA Spill Containment Pallet NA

2920 None NA


Records of monthly visual inspections are maintained by area personnel for at least three years. Section 4.8 establishes the policy for inspection of tanks less than 5,000 gallons capacity.


Complete failure of one food grease tank could result in a 350 gallon spill. An error transferring into a container could spill 5 gallons. The vacuum truck could spill 2,000 gallons. A spill would go to Accotink Creek/Bay, Dogue Creek/Bay, or the Potomac River, depending on where the spill occurred (see Figures 2.1 through 2.7). A spill in any of these areas would trigger the spill response procedures listed in Section 4.7.

Table 5.35.4 Used Food Grease Potential Spill Scenario

Container ID Spill Amount

(Gallons) Contents Cause Pathway

20 200

Food Grease Container Failure

East to the Potomac River 5 Transfer Error

2,000 Vacuum Truck


5-153


(Gallons) Contents Cause Pathway Error

321

200

Food Grease

Container Failure South to the

Potomac River 5 Transfer Error


1135D

240

Food Grease

Container Failure West to Accotink

Bay 5 Transfer Error


1199

200

Food Grease

Container Failure North in storm water piping and

then west to Accotink Bay

5 Transfer Error


1200DR

55

Food Grease

Container Failure West to Dogue



1456B

85

Food Grease

Container Failure West to Accotink



2303

350

Food Grease

Container Failure West and then

south to Accotink Creek

5 Transfer Error


2304E

200

Food Grease

Container Failure South to

Accotink Creek 5 Transfer Error


2444J

200

Food Grease




2462DRB 55 Food Grease Container Failure South to


5-154


(Gallons) Contents Cause Pathway 5 Transfer Error Accotink Creek


2800DRA

55

Food Grease

Container Failure Northeast and

then southeast to Dogue Creek

5 Transfer Error


2920

200

Food Grease





5-155

5.36 Swimming Pool Chemical Containers


There are three swimming pools on Fort Belvoir that use chlorine (sodium hypochlorite solution) for disinfection. The Officer Club pool (Building 75) uses a salt water system where chlorine is a backup while the indoor pool (Building 182) and the north pool (Building 2330) use chlorine as the sole disinfectant. Table 5.36.1 provides details for the pool chemical containers, and the Fort Belvoir Containers and Drainage Map, Figure 2.1, shows locations and flow directions.

Table 5.36.1 Swimming Pool Chemical Containers

Container ID Type

Capacity (Gallons)

Material of Construction Product Stored

75 AST, Vertical 100 Plastic Sodium Hypochlorite 182 AST, Vertical 150 Plastic Sodium Hypochlorite

2330A AST, Vertical 100 Plastic Sodium Hypochlorite 2330B AST, Vertical 60 Plastic Sodium Hypochlorite



The chlorine is delivered by contractors and pumped into the distribution tanks. The tanks are translucent so the level of product in the tanks is always visible. The solution is then added to the water by an automatic metering system with an electric pump. Table 5.36.2 provides more details regarding product handling activities for this area.

Table 5.36.2 Swimming Pool Chemical Product Handling


75 Electric Pump Visual Used in Water Treatment

182 Electric Pump Visual Used in Water Treatment

2330A Electric Pump Visual Used in Water Treatment

2330B Electric Pump Visual Used in Water Treatment


5-156


The tank at 182 is inside a plastic dike, but the other tanks do not have secondary containment. Appendix D contains volume calculations for containers within diked areas. The other containers are all single-walled and do not have secondary containment (See Section 6.0, Corrective Actions).

Table 5.36.3 Swimming Pool Chemical Secondary Containment

Container ID Type Storm Water Release 75 None NA

182 Plastic Dike NA 2330A None NA 2330B None NA


Records of annual visual inspections are maintained by area personnel for at least three years. Section 4.8 establishes the policy for inspection of containers holding chemicals (non-oils) not regulated by 40 CFR 112.


Complete failure of one chemical tank could result in a 150 gallon spill. An error transferring into a container could spill 5 gallons. A spill would go to the Accotink Creek/Bay, Dogue Creek/Bay, or the Potomac River, depending on where the spill occurred (see Figures 2.1 through 2.7). A spill in any of these areas would trigger the spill response procedures listed in Section 4.7.

Table 5.36.4 Swimming Pool Chemical Potential Spill Scenario



75 100 Sodium

Hypochlorite Container Failure East to the


182 150 Sodium

Hypochlorite Container Failure South to the


2330A 100 Sodium

Hypochlorite Container Failure West to Accotink



5-157



2330B 60 Sodium

Hypochlorite Container Failure West to Accotink




6-1

6.0 Corrective Actions.

Facilities that are unable to implement their Corrective Actions within 6 months of certification must submit a written extension request to the Regional Administrator in accordance with the requirements of 40 CFR 112.3(f). Due to the Army’s funding process, Fort Belvoir may not be able to complete these changes within a six-month time period. Fort Belvoir will show a good faith effort through submittal of proper work and funding requests to address these issues.

Table 6.1 shows the new corrective actions required by this Plan. Any updates to the Plan should include Table 6.1 showing the implemented corrective actions.

Table 6.1 Corrective Actions

Corrective Actions Date

Signed Responsible

Party Signature Comment Provide adequate secondary containment for: 331B, 338C, 374A, 374B, 767, 780B, 1412A, 1412B, 1417L, 1950B, 1976C, 2310C, 2310D, 2310E, 2476A, 2800C, 2803B, 2803C, 2809, 2822, 2909A, 2909B.

Secondary containment must be impervious and large enough to hold the entire volume of the container plus enough freeboard for precipitation. Double-walled containers are preferred.

Provide secondary containment for food grease containers at: 20, 321, 1135D, 1199, 1200DR, 1456B, 2303, 2304E, 2444J, 2462DRB, 2920

Provide secondary containment for buried heating oil tanks at 380AU, 1810AU, and 1981U.

Installing impervious secondary containment may not be possible. Replace with double-walled containers (ASTs or completely buried tanks).


6-2


Signed Responsible

Party Signature Comment

Provide secondary containment for drums at: 1956DRC, 2990DR.

Drums are inside but a spill could leave the building.

Provide larger secondary containment for drums at: 2800DRA, 5104DR.

Containment must be at least large enough to hold the volume of a drum (55 gallons).

Provide larger secondary containment for ASTs 324V and 767.

Containment is too small. It must be large enough to hold the entire volume of the tank.

Remove (replace if necessary) ASTs that are heavily corroded: 1822E, 2909A, 2909B

These corroded tanks cannot be determined to maintain structural integrity.

Remove soil to completely expose piping accidentally buried and then visually inspect piping for integrity at tank: 193B, 331B

Piping must remain exposed so that the entire surface can be visually inspected.

Replace level gauges and/or spill buckets at tanks: 331B, 374A, 374B, 600, 606B, 780B, 1109D, 1109E, 1417L, 1417M, 1465A, 1822E, 1906C, 1976C, 2462H, 2590A, 2849, 2909A, 2909B, 2990B, 2990CU, 3138J, 3153A, 9500B.

Level gauges are required (9VAC225-91-130.B.3.d) to prevent spills due to overfills.

Label drums properly for use to contain oil products at 2462DRA

Drums should not be labeled with other hazardous material and/or hazardous waste labels.


6-3


Signed Responsible

Party Signature Comment Provide secondary containment for tanks at: 75, 1234I, 2330A, 2330B, 2444G, 2444H, 2444I, and drums at: 1234DRA, 1234DRB, 2800DRB, 2803DR.

These containers do not contain oil and are only regulated by AR 200-1.


A-1

Appendix A

SPCC Regulated Containers


A-2

Table A-1. SPCC Regulated Containers

Container ID (Building Number)

Capacity (Gallons)


Product Stored

Secondary Containment

TypeFunction

20 200 Steel Used Food Grease None Waste

75 100 Plastic Sodium Hypochlorite None Water Treatment

97 750 Steel Diesel Double-walled Generator

182 150 Plastic Sodium Hypochlorite Plastic Dike Water Treatment

190 500 Steel Used Oil Double-walled Waste

190DRA 55 (up to 6) Steel

Oil, Hydraulic Oil,

Used Oil, Used Fuel Containment

Pallet Dispense, Waste Antifreeze,

Used Antifreeze

190DRB 55 (up to 12) Steel

Oil, Hydraulic Oil Steel Dike Storage

Antifreeze 193B 500 Steel Diesel Double-walled Generator

193CU 1,000 Steel Heating Oil None Heat 200 315 Steel Diesel Double-walled Generator 238 676 Steel Diesel Double-walled Generator

246D 1,000 Steel Diesel Steel Dike Generator 314A 150 Steel Diesel Double-walled Generator 315 150 Steel Diesel Double-walled Generator

319A 475 Steel Diesel Double-walled Generator 319B 475 Steel Diesel Double-walled Generator


324R 2,000 Steel Diesel Double-walled Dispense 324S 250 Steel Used Oil Double-walled Waste 324T 2,000 Steel JP8 Double-walled Dispense 324V 150 Steel Diesel Steel Dike Generator 331B 550 Steel Heating Oil None Heat

331DRA 55 (up to 6) Steel Used Oil Containment

Pallet Waste

331DRB 55 Steel Oil, Steel Dike Dispense


A-3


Capacity (Gallons)


Product Stored


TypeFunction

(up to 8) Hydraulic Oil 332HU 25,000 Steel Heating Oil None Heat/Hot Water 332IU 25,000 Steel Heating Oil None Heat/Hot Water 332JU 25,000 Steel Heating Oil None Heat/Hot Water 338B 300 Steel Gasoline Double-walled Dispense

338C 2,000 Steel Oily Bilge Water Steel Dike Waste

338D 500 Steel Used Oil Double-walled Waste

338M 2,500 (truck) Steel Gasoline Plastic Dike

(when parked) Dispense

338DRA 55 (up to 4) Steel Oil Containment

Pallet Dispense

338DRB 55 (up to 20) Steel Oil,

Hydraulic Oil Steel Conex Storage


341DR 55 (up to 4) Steel Used Oil Containment

Pallet Waste

363C 250 Steel Diesel Double-walled Generator 366C 550 Steel Heating Oil Double-walled Heat/Hot Water 367A 1,500 Steel Diesel Double-walled Generator 367B 240 Steel Diesel Double-walled Generator 374A 275 Steel Heating Oil None Heat/Hot Water 374B 275 Steel Heating Oil None Heat/Hot Water

380AU 1,000 Steel Heating Oil None Heat/Hot Water 380B 475 Steel Diesel Double-walled Generator 399 520 Steel Diesel Double-walled Generator

584A 156 Steel Diesel Double-walled Generator 594B 250 Steel Diesel Double-walled Generator 600 500 Steel Diesel Double-walled Dispense

606A 250 Steel Diesel Double-walled Generator 606B 500 Steel Diesel Plastic Dike Dispense 687B 500 Steel Diesel Double-walled Generator 765A 3,000 Steel Diesel Double-walled Generator 765B 5,000 Steel Diesel Double-walled Generator 765C 700 Steel Diesel Double-walled Generator 767 275 Steel Diesel Concrete Dike Fire Pump

780B 500 Steel Heating Oil None Heat/Hot Water


A-4


Capacity (Gallons)


Product Stored


TypeFunction

952A 250 Steel Diesel Double-walled Generator 1089C 500 Steel Used Oil Double-walled Waste 1109C 500 Steel Kerosene Double-walled Dispense 1109C 500 Steel Diesel Plastic Dike Dispense 1109D 500 Steel Diesel Double-walled Dispense 1114A 5,000 Steel Gasoline Double-walled Dispense 1128B 500 Steel Diesel Double-walled Dispense

1135D 240 Stainless Steel

Used Food Grease None Waste

1141A 550 Steel Heating Oil Double-walled Heat/Hot Water 1142A 550 Steel Heating Oil Double-walled Heat/Hot Water 1143A 550 Steel Heating Oil Double-walled Heat/Hot Water 1143B 550 Steel Heating Oil Double-walled Heat/Hot Water 1156A 112 Steel Diesel Double-walled Generator 1157A 550 Steel Heating Oil Double-walled Heat/Hot Water


1200DR 55 (up to 4) Steel Used Food

Grease None Waste

1204 525 Steel Diesel Double-walled Generator 1234E 600 Steel Diesel Double-walled Generator 1234F 600 Steel Diesel Double-walled Generator 1234G 600 Steel Diesel Double-walled Generator 1234H 600 Steel Diesel Double-walled Generator

1234I 125 Plastic Sodium Hydroxide None Boiler Water

Treatment

1234DRA 65 Plastic Sodium Hypochlorite None Boiler Water

Treatment

1234DRB 55

(up to 4) Plastic

Sodium Hydroxide, Diethanol-

Amine

None Boiler Water Treatment

1250U 25,000 Steel Heating Oil None Heat/Hot Water 1251U 25,000 Steel Heating Oil None Heat/Hot Water 1260 1705 Steel Diesel Double-walled Generator 1262 1705 Steel Diesel Double-walled Generator

1412A 550 Steel Heating Oil None Heat


A-5


Capacity (Gallons)


Product Stored


TypeFunction

1412B 550 Steel Heating Oil None Heat 1417H 500 Steel Motor Oil Double-walled Dispense 1417I 500 Steel Motor Oil Double-walled Dispense 1417J 500 Steel Hydraulic Oil Double-walled Dispense 1417K 500 Steel Used Oil Double-walled Waste 1417L 600 Steel Diesel None Dispense 1417M 600 Steel Diesel Plastic Dike Dispense


Oil, Hydraulic Oil Steel Conex Storage

Antifreeze


Oil, Hydraulic Oil Steel Conex Storage

Antifreeze

1417DRC 55 (up to 8) Steel

Oil,Hydraulic Oil Containment

Pallet Dispense Antifreeze

1417DRD 55 (up to 4) Steel

Used Oil, Used Fuel Containment

Pallet Waste Used Antifreeze

1420A 250 Steel Hydraulic Oil Concrete Dike Dispense 1420B 275 Steel Used Oil Concrete Dike Waste 1420C 275 Steel Oil Concrete Dike Dispense


Used Oil Plastic Dike Waste Used

Antifreeze


Oil, Hydraulic Oil,

Grease Concrete Dike Dispense

Antifreeze 1421B 250 Steel Diesel Double-walled Generator

1422PU 25,000 Steel Heating Oil None Heat/Hot Water 1422QU 25,000 Steel Heating Oil None Heat/Hot Water 1422RU 25,000 Steel Heating Oil None Heat/Hot Water 1422SU 25,000 Steel Heating Oil None Heat/Hot Water 1422TU 25,000 Steel Heating Oil None Heat/Hot Water 1436D 2,000 Steel Heating Oil Double-walled Heat/Hot Water 1444 1,000 Steel Heating Oil Double-walled Heat/Hot Water

1456A 461 Steel Diesel Double-walled Generator


A-6


Capacity (Gallons)


Product Stored


TypeFunction

1456B 85 Steel Used Food Grease None Waste

1462B 250 Steel UsedAntifreeze Double-walled Waste

1462C 500 Steel Used Oil Double-walled Waste

1462DR 55 (up to 4) Steel Used Oil Steel Dike Waste

1465A 250 Steel Diesel Double-walled Generator 1465B 112 Steel Diesel Double-walled Generator 1576 150 Steel Diesel Double-walled Generator 1589 112 Steel Diesel Double-walled Generator

1695A 250 Steel Diesel Double-walled Generator 1696CU 1,000 Steel Heating Oil None Heat/Hot Water 1700AU 5,000 Steel Heating Oil None Heat/Hot Water 1810AU 8,000 Steel Heating Oil None Heat/Hot Water 1822D 250 Steel Diesel Double-walled Generator 1822E 250 Steel Diesel Steel Dike Generator 1832B 250 Steel Diesel Double-walled Generator 1906C 500 Steel Used Oil Double-walled Waste 1906E 500 Steel Heating Oil Double-walled Heat/Hot Water 1949 250 Steel Used Oil Double-walled Waste

1949DR 55 (up to 4) Steel

Oil Containment

Pallet Dispense, Waste Antifreeze, Used

Antifreeze 1950AU 3,000 Steel Heating Oil None Heat/Hot Water 1950B 250 Steel Used Oil None Waste

1950DRA 55 (up to 2) Steel Used

Antifreeze Containment

Pallet Waste


Oil, Hydraulic Oil Steel Conex Dispense

Antifreeze 1956A 500 Steel Used Oil Double-walled Waste 1956B 2,000 Steel Diesel Double-walled Generator


Used Oil Containment Pallet Waste Used

Antifreeze

1956DRB 55 Steel Oil, Hydraulic Oil Steel Conex Storage


A-7


Capacity (Gallons)


Product Stored


TypeFunction

(up to 12) Antifreeze

1956DRC 55 (up to 4) Steel

Oil,Hydraulic Oil Containment

Pallet Dispense Antifreeze

1970D 500 Steel Heating Oil Double-walled Heat/Hot Water 1976C 1,000 Steel Heating Oil None Heat/Hot Water 1980A 500 Steel Heating Oil Double-walled Heat/Hot Water 1981U 550 Steel Heating Oil None Heat/Hot Water 2117U 25,000 Steel Heating Oil None Heat/Hot Water

2303 350 Stainless Steel

Used Food Grease None Waste

2304E 200 Steel Used Food Grease None Waste

2310B 500 Steel Diesel Double-walled Generator 2310C 335 Steel Diesel None Generator 2310D 335 Steel Diesel None Generator 2310E 335 Steel Diesel None Generator

2310DR 55 (up to 4) Steel Oil,

Used Oil Containment

Pallet Dispense, Waste

2330A 100 Plastic Sodium Hypochlorite None Water Treatment

2330B 60 Plastic Sodium Hypochlorite None Water Treatment

2444D 250 Steel Diesel Double-walled Generator 2444E 250 Steel Diesel Double-walled Generator 2444F 250 Steel Diesel Double-walled Generator

2444G 100 Plastic Sodium Hydroxide None Boiler Water

Treatment

2444H 100 Plastic Acetic Acid None Boiler Water Treatment

2444I 100 Plastic Sodium Hypochlorite None Boiler Water

Treatment

2444J 200 Steel Used Food Grease None Waste

2445C 250 Steel Diesel Double-walled Generator 2454A 250 Steel Diesel Double-walled Generator 2462C 300 Steel Diesel Steel Dike Generator 2462D 300 Steel Diesel Steel Dike Generator 2462E 300 Steel Diesel Steel Dike Generator


A-8


Capacity (Gallons)


Product Stored


TypeFunction

2462F 300 Steel Diesel Steel Dike Generator 2462G 300 Steel Diesel Steel Dike Generator 2462H 250 Steel Diesel Double-walled Dispense

2462I 65 Plastic Phosphoric Acid Double-walled Boiler Water

Treatment

2462DRA 55 (up to 4) Steel Used Oil Containment

Pallet Waste

2462DRB 55 (up to 2) Steel Used Food

Grease None Waste

2470 250 Steel Diesel Double-walled Generator 2473BU 5,000 Steel Heating Oil None Heat/Hot Water 2476A 500 Steel Heating Oil None Heat/Hot Water 2494 112 Steel Diesel Double-walled Generator 2580 500 Steel Kerosene Double-walled Dispense

2582BU 2,500 Steel Heating Oil None Heat/Hot Water 2584BU 5,000 Steel Heating Oil None Heat/Hot Water 2590A 500 Steel Diesel Double-walled Generator 2591B 500 Steel Diesel Double-walled Generator

2592DU 5,000 Steel Heating Oil None Heat/Hot Water 2592E 3,225 Steel Diesel Double-walled Generator 2592F 800 Steel Diesel Double-walled Generator 2593C 2,000 Steel Diesel Double-walled Generator 2594E 165 Steel Diesel Double-walled Generator 2594F 800 Steel Diesel Double-walled Generator 2596A 1,369 Steel Diesel Double-walled Generator 2596B 1,369 Steel Diesel Double-walled Generator 2597 105 Steel Diesel Double-walled Generator

2800C 550 Steel Diesel None Heat/Hot Water

2800DRA 55 (up to 4) Steel Used Food

Grease Containment

Pallet Waste

2800DRB 55 (up to 2) Plastic

Sodium Hydroxide, Cyclohexyl-

amine

None Boiler Water Treatment

2803B 550 Steel Diesel None Heat/Hot Water, Dispense

2803C 195 Steel Diesel None Generator


A-9


Capacity (Gallons)


Product Stored


TypeFunction

2803DR 55 Plastic Sodium Hydroxide None Boiler Water

Treatment 2809 415 Steel Diesel None Generator

2810D 2,500 Steel Diesel Double-walled Generator 2822 195 Steel Diesel None Generator 2827 640 Steel Diesel Double-walled Heat/Hot Water

2849A 110 Steel Diesel Double-walled Generator 2849B 500 Steel Diesel Double-walled Dispense 2849C 125 Steel Diesel Double-walled Generator 2857A 140 Steel Diesel Double-walled Generator 2857B 140 Steel Diesel Double-walled Generator 2857C 140 Steel Diesel Double-walled Generator 2857D 140 Steel Diesel Double-walled Generator 2857E 140 Steel Diesel Double-walled Generator 2857F 140 Steel Diesel Double-walled Generator 2857G 140 Steel Diesel Double-walled Generator 2857H 140 Steel Diesel Double-walled Generator 2857I 140 Steel Diesel Double-walled Generator 2857J 140 Steel Diesel Double-walled Generator 2857K 140 Steel Diesel Double-walled Generator 2857L 140 Steel Diesel Double-walled Generator 2857M 140 Steel Diesel Double-walled Generator 2857N 140 Steel Diesel Double-walled Generator 2857O 100 Steel Diesel Double-walled Generator 2857P 100 Steel Diesel Double-walled Generator 2909A 500 Steel Gasoline None Dispense 2909B 500 Steel Gasoline None Dispense



2990A 275 Steel Used Antifreeze Double-walled Waste

2990B 275 Steel Used Oil Double-walled Waste 2990CU 2,000 Steel Heating Oil None Heat/Hot Water

2990DR 55 (up to 12) Steel Oil,

Hydraulic Oil, None Dispense


A-10


Capacity (Gallons)


Product Stored


TypeFunction

Grease Antifreeze

2993C 500 Steel Gasoline Double-walled Dispense 2993D 500 Steel Diesel Double-walled Dispense

2993DRA 30 Plastic Prodiamine Containment Pallet Herbicide

2993DRB Various Plastic Various Pesticides

Containment Pallet

Various Pesticides

3121DRA 55 (up to 12) Steel Used Oil,

Used Fuel Steel Conex Waste

3121DRB 55 (up to 20) Steel Oil,

JP8 Steel Conex Dispense

3138HU 30,000 Steel Heating Oil None Heat/Hot Water 3138IU 30,000 Steel Heating Oil None Heat/Hot Water 3138J 1,000 Steel Diesel Double-walled Generator

3140DR 55 (up to 8) Steel Used Oil,

Used Fuel Containment

Pallet Waste



Pallet Waste



Pallet Waste

3153A 550 Steel Heating Oil Double-walled Heat/Hot Water

3153DR 55 (up to 4) Steel Used Fuel Containment

Pallet Waste

3161A 500 Steel Gasoline Double-walled Dispense 3161B 500 Steel Diesel Double-walled Dispense


Pallet Waste

3161MA 5,000 (truck) Steel JP8 Concrete Dike


3161MB 3,000 (truck) Steel JP8 Concrete Dike


3161MC 3,000 (truck) Steel JP8 Concrete Dike


3161MD 3,000 (truck) Steel JP8 Concrete Dike


3161ME 3,000 (truck) Steel JP8 Concrete Dike


3165A 500 Steel Diesel Double-walled Generator


A-11


Capacity (Gallons)


Product Stored


TypeFunction

3209 250 Steel Diesel Double-walled Generator 3229 250 Steel Diesel Double-walled Generator

3231DR 55 (up to 3) Steel Used Oil Containment

Pallet Waste


Pallet Waste

3238 105 Steel Diesel Double-walled Generator 3239A 250 Steel Diesel Double-walled Generator 3242 500 Steel Diesel Double-walled Generator

DAAF Gate 112 Steel Diesel Double-walled Generator 5101 350 Steel Diesel Double-walled Generator

5103A 400 Steel Diesel Double-walled Generator 5103B 400 Steel Diesel Double-walled Generator 5103C 400 Steel Diesel Double-walled Generator 5103D 400 Steel Diesel Double-walled Generator 5103E 400 Steel Diesel Double-walled Generator 5103F 400 Steel Diesel Double-walled Generator 5103G 400 Steel Diesel Double-walled Generator 5103H 500 Steel Diesel Double-walled Generator 5103I 500 Steel Diesel Double-walled Generator 5103J 500 Steel Diesel Double-walled Generator 5104A 10,000 Steel Diesel Double-walled Generator 5104B 30,000 Steel Diesel Double-walled Generator 5104C 30,000 Steel Diesel Double-walled Generator 5104D 30,000 Steel Diesel Double-walled Generator 5104E 30,000 Steel Diesel Double-walled Generator 5104F 30,000 Steel Diesel Double-walled Generator 5104G 30,000 Steel Diesel Double-walled Generator 5104H 400 Steel Diesel Double-walled Generator

5104I 110 Plastic Glutaraldehyde Plastic Dike Boiler Water Treatment

5104J 110 Plastic Phosphonic Acid

Stainless Steel Dike

Boiler Water Treatment

5104K 110 Plastic Sodium Hypochlorite Plastic Dike Boiler Water

Treatment

5104L 200 Plastic Sodium Hydroxide Plastic Dike Boiler Water

Treatment


A-12


Capacity (Gallons)


Product Stored


TypeFunction

5104DR 55 (up to 4)

Plastic Used Oil Containment Pallet Waste

7336A 250 Steel Diesel Double-walled Generator 7352A 156 Steel Diesel Double-walled Generator 9500A 308 Steel Diesel Double-walled Generator 9500B 500 Steel Kerosene Double-walled Dispense


SPCC Regulated Containers (Continued) (Transformers)


Capacity (Gallons)


Product Stored


TypeT5103A 5,380 Steel Vegetable Oil Concrete Dike T5103B 5,380 Steel Vegetable Oil Concrete Dike T2500A 785 Steel Mineral Oil None T2500B 1,240 Steel Mineral Oil None T2584 225 Steel Mineral Oil None T2592 350 Steel Mineral Oil None T2593 388 Steel Mineral Oil None T2594 365 Steel Mineral Oil None T2596 500 Steel Mineral Oil None


A-13

Table A-2. SPCC-Exempt USTs Subject to 40 CFR 280


Type Capacity (Gallons)

Material of Construction Contents Function

808A UST 5,000 FRP Diesel Generator

1124C UST 12,000 Steel with Coating

E85 (Empty) (Ethanol / Gasoline)

Dispense

1124D UST 12,000 Steel with Coating Used Oil Waste

1124H UST 30,000 FRP Gasoline Dispense 1124I UST 30,000 FRP Diesel Dispense 1135A UST 20,000 FRP Gasoline Dispense 1135B UST 10,000 FRP Gasoline Dispense 1135C UST 10,000 FRP Gasoline Dispense 1252A UST 20,000 FRP Diesel Generator 1253A UST 20,000 FRP Diesel Generator 1254A UST 20,000 FRP Diesel Generator 2119 UST 550 FRP Diesel Generator

2304A UST 12,000 FRP Gasoline Dispense 2304B UST 12,000 FRP Gasoline Dispense 2304C UST 12,000 FRP Gasoline Dispense 2304D UST 12,000 FRP Gasoline Dispense 2310A UST 25,000 FRP Diesel Generator

2444C UST 25,000 FRP Diesel Generator / Heat

2445A UST 30,000 FRP Diesel Generator 2445B UST 30,000 FRP Diesel Generator 2462B UST 25,000 FRP Diesel Generator

2594A UST 5,000 FRP Diesel Generator / Heat


2800B UST 6,000 FRP Diesel Generator / Heat

2803A UST 25,000 FRP Diesel Generator /

Heat / Dispense

2810A UST 25,000 FRP Diesel Generator 2810B UST 25,000 FRP Diesel Generator


A-14

2810C UST 25,000 FRP Diesel Generator 2838A UST 5,000 FRP Gasoline Dispense 2849D UST 5,000 FRP Diesel Never Used



2851C UST 50,000 FRP Diesel Generator / Heat

2851D UST 50,000 FRP Diesel Generator / Heat

2851E UST 50,000 FRP Diesel Generator / Heat

2851F UST 50,000 FRP Diesel Generator / Heat



3162A UST 13,000 FRP JP8 Dispense 3162B UST 13,000 FRP JP8 Dispense


B-1

Appendix B

Certification of the Applicability of the Substantial Harm Criteria


B-2

Certification of the Applicability of the Substantial Harm Criteria (As per 40 CFR 112.20(f) Appendix C)

Facility Name: Fort Belvoir Facility Address: Directorate of Public Works, Environmental Division

ATTN: IMBV-PWE Fort Belvoir, VA 22060

1. Does the facility transfer oil over water to or from vessels and does the facility have a totaloil storage capacity greater than or equal to 42,000 gallons?

Yes ____ No X

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallonsand does the facility lack secondary containment that is sufficiently large to contain thecapacity of the largest aboveground oil storage tank plus sufficient freeboard to allow forprecipitation within any aboveground oil storage tank area?

Yes ____ No X

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallonsand is the facility located at a distance (as calculated using the appropriate formula inAttachment C-III to 40 CFR 112 or a comparable formula) such that a discharge from thefacility could cause injury to fish and wildlife and sensitive environments?

Yes ____ No X

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallonsand is the facility located at a distance (as calculated using the appropriate formula inAttachment C-III to this appendix or a comparable formula) such that a discharge from thefacility would shut down a public drinking water intake?

Yes ____ No X

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallonsand has the facility experienced a reportable oil discharge in an amount greater than orequal to 10,000 gallons within the last 5 years?

Yes ____ No X

Certification

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete.

Signature: Date: _____________

Name: Felix Mariani, Chief, Environmental Division Fort Belvoir


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Appendix C

Discharge Report to US EPA Regional Administrator


C-2

Discharge Report to US EPA Regional Administrator

Facility name and location: Fort Belvoir, Fairfax County, Virginia 22060

Name(s) of the owner or operator of facility:

U.S. Army Garrison Fort Belvoir (IMBV-PWE)

Date and year of initial facility operation: 1915

Maximum storage or handling capacity of the facility & normal daily throughput: Estimated amount of spill and type of oil

Cause(s) of spill, including a failure analysis of system or subsystem in which the failure occurred:

Corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements:

Additional preventive measures taken or contemplated to minimize the possibility of recurrence:

Provide the following:

Task Completed Comments

Description of facility, including maps, flow diagrams, and topographical maps.

The names of individuals and/or organizations also contacted and the date and time contacted.


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Appendix D

Volume Calculations for Secondary Containment Dikes


D-2

Volume Calculations for Secondary Containment Dikes

Container ID Location Container Type

Container Capacity (gallons)

Length (feet)

Width (feet)

Height (feet)

Containment Capacity (gallons)

Percent Containment

Capacity

182 Swimming Pool AST, Vertical 150 Cylinder 4 4 370 246% 246 Emergency Generator AST, Horizontal 1,000 12.75 5.91 2 1,120 112%

324V Emergency Generator AST, Horizontal 150 3.33 3.08 1.58 120 80% 331DRB Drum Storage Drums 55 8 4 0.33 75 136%

338B Fuel Storage AST, Horizontal 300 10 10 1 740 246% 338C Oily Bilge Storage AST, Horizontal 2,000 14.83 7.83 2.66 2,300 115%

338DRB Drum Storage Drums 55 15 8.5 0.5 470 854% 338M Tanker Parking Mobile Refueler 2,500 34.5 11.5 1 2960 118% 606B Fuel Storage AST, Horizontal 500 7 5 2.58 670 134% 767 Fire Pump AST, Horizontal 275 7 6.5 0.5 160 58%

1109D Roads and Grounds AST, Horizontal 500 7 5 2.58 670 134%

1124 DOL Fuel Station Loading/Unloading Rack

Mobile Refueler 5,000 98 3 8 17,500 350%

1417DRA Drum Storage Drums 55 23 8.5 0.5 720 1309% 1417DRB Drum Storage Drums 55 6 6 0.5 130 236% 1420A-C Vehicle Maintenance AST, Horizontal 275 17.5 9 1 1,175 427% 1420DRA Drum Storage Drums 55 17.5 9 1 1,175 2136% 1420DRB Drum Storage Drums 55 4.66 2.83 0.91 85 154% 1956DRB Drum Storage Drums 55 14.5 7 0.5 370 672%

2462C – 2462G DLA AST, Horizontal 300 6 4.66 1.41 300 100%^

2800DRA Drum Storage Drums 55 6 4 0.25 44 80% 2849 Generator AST, Horizontal 110 3.41 2.66 2.5 165 150%

2993DR Pesticides Small Containers 30 24.5 6.5 0.5 590 1966% 3121DRA Drum Storage Drums 55 9 7 0.75 350 636% 3121DRB Drum Storage Drums 55 8 7 0.5 200 363%

3161 DAAF Fuel Station Loading/Unloading Rack

Mobile Refueler 5,000 48 35 0.5 6,200 125%

3161 Tanker Parking Mobile Refueler 5,000 79 18 2 21,000 420% 5103 Transformers Transformers 5,380 39 28 1.83 14,900 276% 5104I Boiler Treatment AST, Horizontal 110 4 3 1.83 160 145% 5104J Boiler Treatment AST, Horizontal 110 5 4 2.25 330 300% 5104K Boiler Treatment AST, Horizontal 110 5 4 2.25 330 300% 5104L Boiler Treatment AST, Horizontal 200 5.5 4.33 2 350 175%

5104DR Drum Storage Drums 55 4.25 2.16 0.5 34 61% 9500B Fuel Storage AST, Horizontal 500 7.33 5.83 1.66 525 105%^

Underlined Bold – secondary containment is not large enough to contain tank contents with adequate freeboard for precipitation (110% of container volume).

^ - containment is covered or inside a building and does not need additional containment for precipitation (100% of container volume is adequate).


E-1

Appendix E

Inspection Checklists


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E-3


E-4


E-5


E-6


E-7


E-8


E-9


E-10


E-11


E-12


F-1

APPENDIX F

Immediate Actions

Not Safe If it can be done Safely and Quickly

Emergency situation detected

Dial 911 (see Tables 2 and 3 for reporting spills)

Assess Safety

1. Leave the area2. Wait for emergency personnel 1. Respond to medical conditions (first aid)

2. Use fire extinguishers if needed3. Contain spills with absorbents andbarriers (protect drains and streams) 4. Shut down equipment/processesEnd

End


F-2


F-3

Additional Considerations for Acid Spills

The highest probability of an acid spill on Fort Belvoir would be sulfuric acid from a vehicle battery. However the largest containers of acid are acetic acid at Building 2444 and phosphonic acid at Building 5104.

Personal Protective Equipment. Persons involved in cleaning up an acid spill must follow MSDS instructions and other applicable SOPs and chemical listing information for all safety, storage, and handling procedures, and should use the following PPE:

Butyl rubber or neoprene 18-inch gauntlet gloves, apron, safety goggles, boots or overshoes, and long-sleeved shirts (no exposed skin).

Full face-piece air purifying respirator (APR) with organic vapor/acid gas cartridges, approved by the National Institute for Occupational Safety and Health (NIOSH) or the Mine Safety and Health Administration (MSHA) if inside an enclosed space, or if the spill is large. A full-face shield can be worn when not wearing an APR and handling a spill.

Spill Control Actions. Spill control actions in the event of an acid spill include the following:

Containment. Contain spilled acid with a ring of absorbent. Acid-specific spill response kits contain socks and mats that start purple, and then turn yellow upon contact with acid. If there is any remaining neutralization potential in the absorbents, the color returns to purple.

Neutralization. Add additional acid-specific mats until the entire spill has been absorbed and neutralized. If all available acid-specific absorbents are exhausted, sodium bicarbonate (baking soda) or sodium carbonate (soda ash) must be added to the liquid spill until it is completely covered. If the spilled acid is a solid pellet, flake, or powder, containerize as much of the material as possible, then add sodium bicarbonate to the remaining material until completely covered. Test with pH paper to ensure a pH reading of 6 to 8 has been achieved.

Cautions. Avoid inhalation of fumes and contact with skin. The neutralization reaction may be violent (frothing, release of heat, and gas production). Control reactions by adding neutralizing agents slowly or through dilution.

Cleanup. Add sawdust or clay absorbent until the acid and neutralizing agents are completely covered. Scoop up spent solid absorbent with a long-handled, non-sparking shovel. Place spent waste in a proper plastic container. The container should be labeled “Acid Waste.”

Personal Decontamination. If a person contacts spilled acid, provide immediate treatment by thoroughly flushing the area with water using an eye wash station or


F-4

shower as appropriate, then transport the victim to the Fort Belvoir Community Hospital. Remove any clothing that the acid has come in contact with or contaminated. If someone ingests the acid or breathes acid fumes, immediately transport them to the Fort Belvoir Community Hospital.


G-1

Appendix G

Reportable Quantities

Chemical

RQ (in

pounds)

Approximate RQ of Liquids (as packaged/used on Fort

Belvoir) Largest Container

on Fort Belvoir Ethylene glycol (in antifreeze) 5,000 Approx. 500 gal 275 gal

Phosphoric Acid 5,000 Approx. 500 gal 65 gal Acetic Acid 5,000 Approx. 500 gal 100 gal

Sodium Hydroxide 1,000 Approx. 1,000 gal 125 gal Sodium

Hypochlorite 100 Approx. 100 gal 110 gal

Diethanolamine 100 Approx. 200 gal 55 gal Triethylamine

(herbicide) 5,000 Approx. 1,000 gal 1 gal

Monosodium Methanearsonate

(herbicide) 1 Approx. 0.5 gal 2.5 gal

2,4-D (herbicide) 100 Approx. 30 gal 2.5 gal

Approximations are appropriate since the amount of a spill is rarely known precisely.

Reportable quantities for substances not listed above can be found at (40 CFR 302.4):

https://www.gpo.gov/fdsys/pkg/CFR-2004-title40-vol26/pdf/CFR-2004-title40-vol26-sec302-4.pdf

Note: RQ is for the pure substance. For instance, when determining whether RQ has been met, a mixture with 10% of a hazardous substance would be 1/10th of the weight of the mixture and thus only a 10 times larger spill (of the mixture) would be reportable.

Example: Sodium Hypochlorite (approximately 10% solution weight/volume)

100 pounds RQ = 1000 pounds of solution required to meet RQ 0.10 NaOCl in solution

Density of solution is 9.26 pounds/gallon

1000 pounds of solution required to meet RQ = 108 gallons … or about 100 gallons 9.26 pounds/gallon




H-1

Appendix H

Oil Spill Response Organizations

This list is intended for information purposes only and is not exhaustive, is ordered alphabetically for easy reference (not to signify order of calling), and does not imply any existing or potential contracts or obligations with any portion of the U.S. Government. Any or all of these OSROs could be called in the case of a spill beyond the capacity of onsite response/cleanup personnel/equipment.

OSRO Contact Phone Number

ACE Environmental Services 24-Hour Emergency Service or Response:

1 (410) 354-8030 or 1 (866) 750-4223

Clean Harbors 24-Hour Emergency Service or Response:

1 (800) 645-8265 [1-800-OIL-TANK]

FCC Environmental 24-Hour Emergency Service or Response:

1 (410) 365-8364

IMS/HEPACO 24-Hour Emergency Service or Response:

1 (800) 888-7689

National Response Corporation 24-Hour Emergency Service or Response:

1 (800) 899-4672


I-1

Appendix I

Satellite Locations SPCC Plans

Documents

Fort Belvoir Spill Prevention, Control, & Countermeasure Plan